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South Korean Government Microwave Frequencies Agreement - DOC

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					INTERIM REPORT
3G SPECTRUM STUDY
2500-2690 MHz BAND




                     APPENDICES

                        FOR

                     SECTION 1




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                                             APPENDIX 1.1

                            PLAN TO SELECT SPECTRUM
                   FOR THIRD GENERATION (3G) WIRELESS SYSTEMS
                               in the UNITED STATES
                                    October 20, 2000

I. PRESIDENTIAL MEMORANDUM (PM)

President Clinton signed a memorandum dated October 13, 2000, (Attachment 1) that states the need and
urgency for the United States to select radio frequency spectrum to satisfy the future needs of the citizens
and businesses for mobile voice, high speed data, and Internet accessible wireless capability; the guiding
principles to be used for the development of 3G wireless systems; and the direction to the Federal
agencies to carry out the selection of spectrum.

In summary, the President directed

       the Secretary of Commerce in cooperation with the Federal Communications Commission (FCC)
        to:

               develop a plan by October 20, 2000, for the identification and analysis of possible
                spectrum bands for 3G services that would enable the FCC to select specific frequencies
                by July 2001 for 3G and complete the auction for licensing 3G wireless providers by
                September 30, 2002.
               issue an interim report by November 15, 2000, on the current spectrum uses, and the
                potential for the sharing or segmenting, of two of the bands identified at the World
                Radiocommunication Conference (WRC-2000) for 3G wireless use, 1755-1850 MHz and
                2500-2690 MHz, about which the United States does not have sufficient knowledge at
                present to make a considered decision about allocation.
               work with government and industry representatives through a series of public meetings
                to develop recommendations and plans for identifying spectrum for 3G wireless systems.

       the Secretary of Defense, Secretary of the Treasury, Secretary of Transportation, Department of
        State and heads of any other executive department or agency that currently use any of the
        spectrum identified at the WRC-2000 for 3G systems to participate and cooperate with the
        government-industry group as established above by the Secretary of the Commerce.

       the Department of State to coordinate and present the evolving views of the United States to
        foreign governments and international bodies.

All of the above work is expected to lead to the issuance of a final report by March 1, 2001, that
describes the potential use of all identified bands for 3G wireless applications.

The President encouraged the FCC to participate in the government-industry program being led by the
Secretary of Commerce and complete rulemaking for spectrum allocation in full coordination with the
Assistant Secretary of Commerce for Communications and Information (Administrator, National
Telecommunications and Information Administration (NTIA)) by July 2001.




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II. BACKGROUND

Over the past decade, there has been enormous worldwide growth in the use of mobile radios. Studies in
the International Telecommunication Union (ITU) and elsewhere indicate that this growth in personal
communications is likely to continue. First and second generations of personal communications service
(PCS) are operating now. The 3G PCS will provide mobile and satellite-based broadband capabilities,
and represent a path for the evolution of existing cellular and PCS. A summary of various
administrations' spectrum usage (cellular and PCS) and planned 3G wireless is shown in Attachment 2.

The ITU Radiocommunication Sector has addressed the characteristics of a 3G system and has termed it
International Mobile Telecommunications-2000 (IMT-2000). Key features of IMT-2000 include: a high
degree of commonality of design worldwide; compatibility of services within IMT-2000; and high-
quality worldwide use and roaming capability for multi-media applications (e.g. video-teleconferencing
and high-speed Internet access). The following was considered by the ITU's 2000 WRC-2000: "review of
spectrum and regulatory issues for advanced mobile applications in the context of IMT-2000, noting that
there is an urgent need to provide more spectrum for the terrestrial component of such applications and
that priority should be given to terrestrial mobile needs, and adjustments to the Table of Frequency
Allocations as necessary"(1).

The 698-960 MHz, 1710-1885 MHz, 2500-2690 MHz and the 2700-2900 MHz bands were some of the
bands that WRC-2000 considered for IMT-2000 terrestrial systems. The United States position for this
conference was established among U.S. industry and government representatives, resulting in a proposal
that the United States believed could be the basis for a compromise at the conference, given the
conflicting positions of many of the other administrations. The United States and many ITU Region II
administrations proposed no change to the allocations in the 2700-2900 MHz band. The United States
also suggested three possible bands for terrestrial IMT-2000, including the 1710-1885 MHz band
(favored by the Americas), the 2500-2690 MHz band (favored by Europe), and the 698-960 MHz band.
At the conference, the United States stated that it would study the 1755-1850 MHz and 2500-2690 MHz
bands domestically to (1) see if there are alternate bands to relocate the existing systems, (2) determine
the costs of any required relocation, (3) identify who would pay for relocation, and (4) assess how long
the transition would take. The United States proposed, and the WRC-2000 adopted, full regulatory
flexibility, giving each administration the right to determine which band it may want to identify for IMT-
2000, if it wants to do so at all. Administrations can identify these bands at any time. Also, the United
States proposed to keep bands identified for IMT-2000 open to any technology that fits in the mobile
service rather than specifying a technology or standard for use in the spectrum.

WRC-2000 identified the 806-960, 1710-1885, and 2500-2690 MHz bands for terrestrial IMT-2000. The
1525-1559, 1610-1660.5, 2483.5-2500, 2500-2520 and 2670-2690 MHz bands were identified for the
satellite portion of IMT-2000. These bands are shown in Attachment 2. The conference also adopted a
resolution pointing out that some countries may implement IMT-2000 in the 698-806 and 2300-2400
MHz bands. The WRC-2000 agreed that the identification of these bands does not preclude the use of
these bands by any application of services to which they are allocated, and does not establish priority in
the Radio Regulations. Administrations can implement any bands in any timeframe, for any service or
technology, and may use any portion of the bands that they deem appropriate, based on national
requirements. All of these bands are used at present. For those who may be required to relocate,
additional spectrum may have to be found or other accommodations will have to be made to continue
their operations.




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The United States recognizes that discussions relative to spectrum for advancing mobile
telecommunications systems are vital for administrations to plan their spectrum use, and for industry to
plan how it will meet the marketplace needs of the future. The United States supports the development
and implementation of advancing mobile telecommunications systems, such as IMT-2000, as critical
components of the communications and information infrastructure of the future.

In addition to the three WRC-2000 bands, other bands that could be considered in the United States are:
698-746, 746-764, 776-794, 806-960 (includes the present U.S. cellular), 1710-1850, 1850-1990 (present
PCS bands), 2110-2150, 2160-2165 and 2500-2690 MHz. A brief description of these bands is contained
in Attachment 3. All these bands will be given full consideration in the formulation of the final
allocation order. For some of these bands, no extensive studies are required to provide decision-makers
with a factual basis for a decision. However, in order to achieve a full understanding of all the options
available, the FCC and NTIA need to undertake studies of the frequency ranges of 1755-1850 MHz and
2500-2690 MHz. The studies' purpose is to determine whether, and under what conditions, these bands
could be made available for 3G wireless systems and the costs and operating impacts to the incumbent
users. These analyses are the subject of the study plan described below.

III. STUDIES

A. Overview

The NTIA will study the 1755-1850 MHz band, and the FCC will study the 2500-2690 MHz band. It is
important that the studies be based on the same assumptions where applicable and address common
spectrum options. The two studies will proceed along the same timelines and use similar assumptions to
assure equal treatment for both.

The results of the two studies, relevant information regarding the other bands identified in Section II,
above, (806-960, 1710-1755, 2110-2150, 2160-2165 MHz) and public comment generated either during
the Secretary of Commerce's government-industry dialogue (see Section IV, "Outreach," below) or in
response to the FCC's Notice of Proposed Rulemaking will be taken into consideration when reviewing
the overall spectrum requirements and future plans for 3G. Among other things, there will be an
evaluation of private sector plans to migrate their 1G and 2G systems to 3G in the existing bands they
already have. National security and public safety will also be taken in account. In addition, among other
factors, the U.S. will also have to consider the ramifications of the deployment of 3G elsewhere in the
world with regard to possible spectrum harmonization that could lead to global roaming.

The analysis will also have to take into account the provisions of the FY 00 National Defense
Authorization Act, which requires that before there can be any reallocation of spectrum where the
Department of Defense is a primary user, which includes 1755-1850 MHz, certain conditions must be
met: (1) NTIA, in consultation with the FCC, must identify and make available to the Department of
Defense an alternative band or bands of frequencies as a replacement; and (2) the Secretary of
Commerce, the Secretary of Defense, and the Chairman of the Joint Chiefs of Staff have jointly certified
to specified committees of the Congress that the replacement band or bands of frequencies provides
comparable technical characteristics to restore essential military capability that will be lost as a result of
this reallocation. The same analysis will apply if the DoD is a primary user of a band selected as an
alternate band in which to place incumbent users of the candidate bands.




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B. Study Information Basic Requirements

   1. 3G System Description. The study will describe 3G system requirements and include: (1) nature
   of proposed use; (2) system technical characteristic description (as a minimum, the necessary
   information to perform sharing studies with candidate band systems); (3) spectrum required
   including channeling bandwidths and overall spectrum plans (includes segmentation of candidate
   bands) to cover regions or nationwide; (4) timing requirements for identification of spectrum; (5)
   planned geographical deployments; (6) interference thresholds (ITU based if available); (7) potential
   relationship with other countries' deployment of 3G and global roaming; (8) potential alternate
   spectrum band plans including any band segmentation; and (9) any operational considerations that
   will have a bearing on the evaluation of the sharing/relocation options below. FCC will provide this
   description.

   2. Candidate Band Incumbent System Description. The studies will describe incumbent systems
   in the candidate bands including: (1) nature of use (what it is used for); (2) system technical
   characteristics description (as a minimum, the necessary information to perform sharing studies with
   3G systems); (3) spectrum currently used, including channeling bandwidths and overall spectrum to
   cover regions or nationwide; (4) current geographical deployments; (5) planned geographical
   deployments; (6) system life expectancy; (7) planned replacement systems; (8) interference
   thresholds (ITU based if available); (9) unique operational features (e.g., it has to be located in a
   specific location, area or elevation; or it has a special relationship with other frequency bands such as
   a set separation between uplinks and downlinks); and (10) any operational considerations including
   national security and public safety that will have a bearing on the evaluation of the sharing or
   relocation options above. If any of the above information is classified or non-releaseable under the
   Freedom of Information Act or any other legislation, it will not be released to the public or contained
   in any unrestricted report. This information and subsequent use will be contained in a separate report
   accessible only to those having the necessary security clearances and/or need-to-know. FCC will
   provide the report on the 2500-2690 MHz band and the NTIA will provide the report on the 1755-
   1850 MHz band.

   3. Potential Alternate Bands. When selecting alternate bands for incumbent users of candidate
   bands, consideration should first be given to those bands in which no, or minimum, disruption would
   occur to the incumbents in those bands. Also, the potential alternate bands should afford candidate
   band incumbent systems that may require replacement spectrum the capability to function without
   loss of functionality or necessary interoperability in the alternate band(s). The study will describe the
   alternate bands as to: (1) existing rules and regulations that govern the use of the bands; (2) the
   changes in allocation rules and regulations that would be necessary to make them acceptable to the
   candidate band incumbent users; (3) the relocation of alternate band incumbents if necessary; (4) the
   operational constraints on the alternate band incumbents or on the candidate band systems; and (5)
   any other considerations, including national security and public safety, in the use of the alternate
   bands that would have a negative effect on candidate band incumbent users.


C. Spectrum Sharing/Relocation Options

Using the information above, the study will include a technical evaluation of the following
sharing/relocation options:

   1. System Sharing. An evaluation of the current and planned systems in the candidate bands to share
   with 3G systems.


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    2. Band/Channel Segmentation.

        The studies will assess the feasibility of dividing the candidate bands into segments and/or
        channels and evaluating how the incumbent and 3G systems would share these segments and/or
        channels to meet their respective radiocommunication requirements. The FCC will propose
        possible segmentation plans for both 1755-1850 and 2500-2690 MHz bands to evaluate as part of
        the interim band studies. These options may also consider use of the 1710-1755 and 2110-2160
        MHz segments. Additional segmentation possibilities may be evaluated later in the process. 3G
        alternate plans and 1G/2G migration could have a bearing on this option.

        Studies for both sharing and segmentation will use generally-accepted interference protection
        criteria, where available, for determining unacceptable levels of interference. Studies will also
        consider possible operational methods to mitigate potential interference while retaining the
        capability to perform the same mission or service in light of current requirements.

    3. Band/Channel Segmentation & Alternate Band Combination. If the candidate bands could not
    support all requirements of the incumbents and 3G simultaneously, identification of alternate bands
    to satisfy requirements would be required.

    4. Alternate Bands Only. Relocate incumbents to other bands if necessary.

    5. Other Options. Potential combination of the above.

For each of options above, the evaluation will consider implementation of the option by the end of 2003,
2006, 2010 or any other variant that is costed out above.


D. Cost and Benefits

    1. Option Implementation Cost Estimates. For each of the options in C. above, a cost estimate will
    be provided to include a description of the costs to implement the option or any iterations thereof and
    any associated assumptions. The estimates will include implementing the option by the end of 2003,
    2006, 2010, or at times where there is a potential cost advantage to do so (an example might be that
    an incumbent system is scheduled to relocate to a different band in the future and there would be no
    new cost to relocate the incumbent; or by stopping any further build-outs of systems thereby reducing
    the costs to relocate future incumbents).

    2. Benefits. An estimate will be made of the benefits, if any, including potential auction receipts that
    could be potentially realized as a result of the auction of the spectrum selected for 3G as well as the
    economic benefits. The assumptions made in the estimates will also be described. There may be a
    number of band options to be estimated.

    3. Cost and Benefits Analysis. Based on 1 and 2 above, OMB/FCC/NTIA will perform a cost and
    benefits analysis for each option and implementation timeframe. An independent audit may be
    appropriate to evaluate the cost estimates.

    4. Costing Rules. Both the FCC and NTIA will use consistent cost standards. OMB may have to
    delineate the portions of the cost estimates that may be disallowed.



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E. Schedule

    1. 3G Description. FCC will provide the 3G description to NTIA so the options can be evaluated and
    reports completed as scheduled below.

    2. Reports and Content.

            a. Interim Report - Nov 15, 2000

                    (1) 3G description
                    (2) candidate band incumbent system description
                    (3) evaluation of system sharing and band segmentation options

            b. Final Report - Mar 01, 2001

                    (1) information from Interim Report
                    (2) information on other bands
                    (3) description of alternate bands/relocation studies
                    (4) evaluation including costing and migration schedule for three time periods
                    (2003, 2006, & 2010) for the two options in the interim report and the other options
                    (segmentation & alternate band combination, alternate bands only, and other sharing/
                    segmentation/alternate band mixes)

            c. Other Information - As required

IV. OUTREACH

The President's Memorandum instructs the Secretary of Commerce to work with government and
industry representatives through a series of regular public meetings to develop recommendations and
plans for identifying spectrum for 3G wireless systems. Additionally, it directs the Federal agencies that
use the spectrum, and urges the FCC, to participate and cooperate with the government-industry group.
NTIA, on behalf of the Secretary of Commerce, will act as the primary facilitator in the Department's
outreach program. Each Federal agency will designate a person to represent the agency to attend these
public meetings. The following activities are planned to carry out the President's direction:

    A. Initial Ideas and Positions. NTIA will invite industry representatives to articulate their ideas and
    positions for selection of spectrum for 3G and to suggest industry initiatives to supplement this plan.
    Areas of discussion could include anticipated 3G spectrum requirements, band segmentation,
    1G/2G/2.5G migration, alternate bands for incumbents, short and long range plans, and global
    roaming considerations. Representatives will be asked to submit their ideas and positions in writing.
    NTIA, on behalf of the Secretary of Commerce, will schedule an opportunity for industry
    representatives to explain their ideas and positions. Based on this initial information, subsequent
    meetings may be held.

    B. Interim Reports. The FCC and NTIA will release their interim reports to the public on November
    15. NTIA will ask industry for comments. Subsequent meetings may be held depending on the nature
    of the comments.




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    C. FCC Notice of Proposed Rulemaking (NPRM). The FCC plans to release a NPRM on 3G in
    December which will include information from the interim reports. The FCC will receive comments
    on the NPRM. The FCC and NTIA will hold joint information exchange meetings with industry
    representatives relative to the comments.

    D. Final Report. The FCC and NTIA will release their final reports on March 1, 2001, describing all
    identified bands for 3G wireless use. Industry will be asked to comment on these reports.

V. FCC PROCESS DESCRIPTION AND PLAN

The FCC is responsible for allocating spectrum for non-government uses. The Commission allocates
spectrum through the rule making process in accordance with the Administrative Procedures Act. The
process generally begins when an organization or member of the public submits a petition for rule
making requesting a change in the United States Table of Frequency Allocations contained in Section
2.806 of the FCC rules. The Commission issues a public notice inviting comment on such petitions. If the
Commission finds that the petition has merit, it issues a Notice of Proposed Rule Making (NPRM). The
public is afforded an opportunity to file comments which the Commission must consider before arriving
at a final decision. The Commission then adopts a Report and Order that makes changes to the Table of
Frequency Allocations as appropriate.

The Commission recently received two petitions for rule making requesting spectrum allocations for 3G
mobile services. The Cellular Telecommunications Industry Association (CTIA) submitted a petition
(RM-9920) asking the Commission to allocate spectrum for 3G terrestrial mobile services, and in
particular to conduct studies to consider use of the 1755-1850 MHz and 2500-2690 MHz bands identified
at WRC-2000. The Satellite Industry Association (SIA) submitted a petition (RM-9911) asking the
Commission to allocate the 2500-2520 MHz and 2670-2690 MHz bands for the mobile satellite service
for the mobile component of 3G services. Comments were filed on both petitions on September 12, 2000.

The Commission plans to initiate a Notice of Proposed Rule Making by the end of this year proposing
spectrum allocations for fixed and mobile services that would be available for 3G terrestrial mobile
services. It is anticipated that the Notice of Proposed Rule Making will consider the frequency bands
identified in attachment 1. Further, the NPRM is expected to consider the future role of the cellular and
PCS services in providing 3G services. The NPRM may consider other relevant frequency bands that
may be used to serve the demand for 3G terrestrial services. A number of factors will be considered in
developing proposed allocations, including the studies of 1755-1850 MHz and 2500 - 2690 MHz bands.

A Report and Order (R&O) is planned to be completed by July 2001 allocating spectrum for fixed and
mobile services that will be available for 3G services. The allocation decisions will be based on the
comments filed on the Notice of Proposed Rule Making and studies of the 1755 -1850 MHz and 2500 -
2690 MHz bands, and any other relevant information.

The Commission routinely coordinates frequency allocations that may affect government use of the
spectrum with the NTIA. Because certain of the frequency bands of interest are allocated to the Federal
Government, the Commission will closely coordinate both the NPRM and R&O with NTIA.

The spectrum allocation proceeding will be followed by another rule making proceeding to establish
service rules. The service rule proceeding will be completed in time to complete auctions of the licenses
by September 30, 2002.




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VI. OVERALL SCHEDULE.

 A. Oct 13, 2000             President signs Memorandum to set the major milestones and guidance to
                             the Federal Agencies and FCC

 B. Oct 20, 2000             Secretary of Commerce releases a plan to select spectrum for 3G to the
                             public

 C. Oct 20-Nov15, 2000       Industry shares its ideas, positions, & supplemental plans on 3G spectrum
                             selection.

 D. Nov 15, 2000             Secretary of Commerce and the FCC release their Interim band studies

 E. Nov 15-30, 2000          Industry provides comments on Interim Reports.

 F. Dec 31, 2000             FCC releases Notice of Proposed Rule Making (NPRM) to address 3G
                             allocation issues.

 G. Mar 1, 2001              Final FCC/NTIA band studies completed and final reports describing all
                             identified bands for 3G wireless use made available for public comment

 H. Mar 1 - Jun 15, 2001     NTIA/FCC will have information exchange meetings with industry.

 I.   Mar 1 - Jun 15, 2001   NTIA/FCC will meet regularly during the formulation of the allocation
                             order, and final draft will be coordinated between them.

 J. Jul 30, 2001             FCC issues an allocation order (specifies the bands selected for 3G) and a
                             FNPRM on service & auction rules for allocated bands

 K. Dec 15, 2001             FCC issues Service & Auction rules for allocated bands

 L. Jun 15, 2002             FCC conducts the auction of 3G spectrum

 M. Sep 30, 2002             Assignment of licences for 3G spectrum is completed.

Those items in "bold" are the major milestones that are contained in the President's Memorandum.




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                            ATTACHMENT 1 TO APPENDIX 1.1

THE WHITE HOUSE

Office of the Press Secretary
_________________________________________________________________
For Immediate Release October 13, 2000

October 13, 2000

MEMORANDUM FOR THE HEADS OF EXECUTIVE DEPARTMENTS AND
AGENCIES

SUBJECT: Advanced Mobile Communications/Third Generation Wireless Systems

The United States and the rest of the world are on the verge of a new generation of personal
mobile communications, as wireless phones become portable high-speed Internet connections.
The United States Government must move quickly and purposefully so that consumers, industry,
and Government agencies all reap the benefits of this third generation of wireless products and
services.

In less than 20 years, the U.S. wireless industry has blossomed from virtually nothing to one with
100 million subscribers, and it continues to grow at a rate of 25 to 30 percent annually. Globally,
there are over 470 million wireless subscribers, a number expected to grow to approximately 1.3
billion within the next 5 years. It is an industry in which U.S. companies have developed the
leading technologies for current and future systems. It is an industry whose products help people
throughout the world communicate better and in more places, saving time, money, and lives.

Many saw the first generation of wireless -- cell phones -- as an extravagant way to make
telephone calls. Yet as with all communications systems, the value of wireless communications
increased as the number of users and types of use increased. Today's second generation wireless
technology increased services and information offered to users and increased competition among
providers. Digital "personal communications services" provide added messaging and data
features, including such services as voice mail, call waiting, text messaging, and, increasingly,
access to the World Wide Web. These first and second generation services increased productivity
and reduced costs for thousands of businesses as well as Government agencies.

The next generation of wireless technology holds even greater promise. Neither the first nor the
second generation of wireless technologies were designed for multi-media services, such as the
Internet. Third generation wireless technologies will bring broadband to hand-held devices.
Higher speeds and increased capability will lead to new audio, video, and other applications,
which may create what many are calling "mobile-commerce" (m-commerce) that people will use
in ways that are unimaginable today. Moreover, an international effort is underway to make it
possible for the next generation of wireless phones to work anywhere in the world.

The Federal Government has always played a crucial role in the development of wireless
services. To foster the development of cellular telephone service, the Federal Government made
available radio frequency spectrum that had previously been used by other commercial and
Government services. For the second generation -- digital PCS -- the Federal Government



                                              A-10
allocated spectrum in bands occupied by private sector users, and ensured competition by
awarding numerous licenses, while maintaining technology neutrality.

The United States has also placed a high value on promoting Internet access. Government
support for the development of third generation wireless systems will help combine the wireless
revolution with the Internet revolution. As part of these efforts, radio spectrum must be made
available for this new use. The United States has already been active by, among other things,
participating at the World Radiocommunication Conference 2000 (WRC-2000) earlier this year.
WRC-2000 adopted the basic principles of the U.S. position, which was negotiated by Govern-
ment and industry stakeholders: (1) governments may choose spectrum from any one or all of the
bands identified for third generation mobile wireless; (2) governments have the flexibility to
identify spectrum if and when they choose; and (3) no specific technology will be identified for
third generation services. This result will allow deployment of the best technologies and permit
the United States to move forward with rapid deployment of third generation services in a way
that advances all U.S. interests.

The spectrum identified by international agreement at WRC-2000, however, is already being
used in the United States by commercial tele-communications, television, national defense, law
enforcement, air traffic control, and other services. Similar difficulties in making spectrum
available for third generation mobile wireless systems are evident in other parts of the world.
Because different regions have already selected different bands, there almost certainly will be a
few preferred bands rather than a single band for third generation services. In the United States,
Federal Government agencies and the private sector must work together to determine what
spectrum could be made available for third generation wireless systems.

Accordingly, I am hereby directing you, and strongly encouraging independent agencies, to be
guided by the following principles in any future actions they take related to development of third
generation wireless systems:

-- Third generation wireless systems need radio frequency spectrum on which to operate.
Executive departments and agencies and the Federal Communications Commission (FCC) must
cooperate with industry to identify spectrum that can be used by third generation wireless
systems, whether by reallocation, sharing, or evolution of existing systems, by July 2001;

-- Incumbent users of spectrum identified for reallocation or sharing must be treated equitably,
taking national security and public safety into account;

-- The Federal Government must remain technology-neutral, not favoring one technology or
system over another, in its spectrum allocation and licensing decisions;

-- The Federal Government must support policies that encourage competition in services and that
provide flexibility in spectrum allocations to encourage competition; and

-- The Federal Government must support industry efforts as far as practicable and based on
market demand and national considera-tions, including national security and international treaty
obligations, to harmonize spectrum allocations regionally and internationally.




                                              A-11
I also direct the relevant agencies as follows:

1. I direct the Secretary of Commerce to work cooperatively with the FCC, as the agencies within
the Federal Government with shared responsibility and jurisdiction for management of the radio
frequency spectrum, to develop, by October 20, 2000, a plan to select spectrum for third
generation wireless systems, and to issue, by November 15, 2000, an interim report on the
current spectrum uses and potential for reallocation or sharing of the bands identified at WRC-
2000 that could be used for third generation wireless systems, in order that the FCC can identify,
in coordination with the National Telecommunications and Information Administration,
spectrum by July 2001, and auction licenses to competing applicants by September 30, 2002.

2. I also direct the Secretary of Commerce to work cooperatively with the FCC to lead a
government-industry effort, through a series of regular public meetings or workshops, to work
cooperatively with government and industry representatives, and others in the private sector, to
develop recommendations and plans for identifying spectrum for third generation wireless
systems consistent with the WRC-2000 agreements, which may be implemented by the Federal
Government.

3. I direct the Secretaries of Defense, the Treasury, Transportation, and the heads of any other
executive department or agency that is currently authorized to use spectrum identified at WRC-
2000 for third generation wireless services, to participate and cooperate in the activities of the
government-industry group.

4. I direct the Secretary of State to participate and cooperate in the activities of the government-
industry group, and to coordinate and present the evolving views of the United States
Government to foreign governments and international bodies.

Furthermore, I strongly encourage the FCC to participate in the government-industry outreach
efforts and to initiate a rule-making proceeding to identify spectrum for third generation wireless
services that will be coordinated with the Assistant Secretary of Commerce for Communications
and Information during the formulation and decisionmaking process with the goal of completing
that process by July 2001, so that such spectrum can be auctioned to competing applicants for
licenses by September 30, 2002.


WILLIAM J. CLINTON

##




                                                  A-12
ATTACHMENT 2 TO APPENDIX 1.1
     SPECTRUM CHARTS




            A-13
A-14
A-15
A-16
                               ATTACHMENT 3 TO APPENDIX 1.1
                             Spectrum Use Summary in the United States
                                        (October 18, 2000)

1. 698-746 MHz (TV channels 52 - 59) Band. This spectrum is allocated in Region 2, which includes
the United States, on a primary basis to the Broadcasting and on a secondary basis to the Fixed and
Mobile Services. In addition, within the 698-746 MHz band segment, assignments may be made to
television stations using frequency modulation in the Broadcasting-satellite Service subject to agreement
between administrations concerned and those having services that might be affected. This spectrum is
currently designated as TV channels 52-59 and is used by existing analog full service stations, Low
Power TV stations, TV translator and booster stations, and new DTV television stations. In the United
States, this band is allocated on a primary basis to the Broadcasting Service. This band is also allocated
to the Fixed Service to permit subscription television operations. Further, TV broadcast licensees are
permitted to use subcarriers on a secondary basis for both broadcast and non-broadcast purposes. The
Balanced Budget Act of 1997 requires this spectrum to be reallocated and auctioned by September 30,
2002. Existing TV service and the service of new digital television (DTV) stations will continue on
channel allotments in this band until at least December 31, 2006, when the transition to DTV service is
scheduled to end and all television stations are to be located on channels in the DTV core spectrum
(Channels 2-51). Television stations will cease operations on these channels at the end of the DTV
transition, or possibly later on a market-by-market and channel-by-channel basis, depending on the
availability of DTV television service and receivers. The rules for any new services on 698-746 MHz
frequencies provide for the protection of those stations during the DTV transition. The WRC results
recognize that some administrations may choose to provide for 3G services in this spectrum.

2. 746-806 MHz (TV Channels 60-69) Band. The Federal Communications Commission (FCC) has
reallocated this spectrum in accordance with the 1997 Balanced Budget Act. Specifically, the 36
megahertz of spectrum at 746-764 MHz and 776-794 MHz (TV channels 60-62 and 64-66) was
reallocated for fixed, mobile and new broadcast services for commercial uses. The 24 megahertz of
spectrum at 764-776 MHz and 794-806 MHz (TV channels 63-64 and 68 - 69) were reallocated to the
fixed and mobile services for use by public safety. Segments of the 746-764 MHz and 776-794 MHz
bands, totaling 6 megahertz and referred to as the public safety guard bands, were recently auctioned.
Cellular-type systems are prohibited in the guard bands in order to protect public safety operations
against adjacent channel interference, and therefore this spectrum is not suitable for 3G systems.
However, the remaining 30 megahertz of spectrum may be used for 3G services. This spectrum is
planned for auction by March 6, 2001. The WRC results recognize that some administrations may choose
to provide for 3G services in this spectrum.

3. 806-960 MHz Band. WRC 2000 adopted a footnote S5.XXX to the international table of frequency
allocation stating that Administrations wishing to implement International Mobile Telecommunications-
2000 (IMT-2000) may use those parts of the band 806-960 MHz which are allocated to the mobile
service on a primary basis and are used or planned to be used for mobile systems (see Resolution 224
(WRC-2000)). The footnote also states that this identification does not preclude the use of these bands by
any application of the services to which they are allocated and does not establish priority in the Radio
Regulations. In keeping with its principle that existing mobile operators should be free to evolve to IMT-
2000 and beyond as the market demands, any band available for 1st or 2nd generation systems is also
available in the United States for IMT-2000 or other advanced communications applications. In the
United States, these bands include 806-821 / 851-866 MHz for the Specialized Mobile Radio Services
(SMRs) and 824-849 / 869-894 for the cellular radio service. The Commission's planned Notice of
Proposed Rule Making is expected to consider the extent to which the existing SMR and cellular radio



                                                  A-17
services may meet the demand for 3G services. The Notice may also consider parts of the 806 - 960 MHz
band that are used by other radio services.

4. 1710-1755 MHz Band. This band is currently allocated on a primary basis for Federal Government
Fixed and Mobile Services. In addition, radio astronomy services may use the 1718.8-1722.2 MHz band
segment on an unprotected basis. This band is currently used for Government point-to-point microwave
communications, military tactical radio relay, and airborne telemetry systems. NTIA identified this
spectrum for transfer to the FCC for non-government use, effective in 2004, to satisfy the requirements of
the Omnibus Budget Reconciliation Act of 1993 (OBRA 93). NTIA indicates that, as required under
OBRA 93, all microwave communication facilities in the 1710-1755 MHz band that are operated by
Federal power agencies will continue to operate in the band and must be protected from interference. A
list of exempted Federal power agency microwave systems, as well as 17 Department of Defense sites, is
presented in Appendix E of the 1995 NTIA Spectrum Report. The Balanced Budget Act of 1997 (BBA
97) requires this spectrum to be assigned for commercial use by competitive bidding, with the auction to
commence after January 1, 2001 and to be completed by September 30, 2002.

5. 1755-1850 MHz Band. The 1755-1850 MHz band supports four main Federal functions; space
telecommand, tracking and control (TT&C, or space operations), medium capacity fixed microwave,
tactical radio relay training, and aeronautical mobile applications such as telemetry, video and target
scoring systems. This band is allocated on an exclusive basis to the Federal Government for fixed and
mobile services, and in the 1761-1842 MHz portion, used for space operations. Fixed links are operated
by federal agencies for voice, data, and/or video communications where commercial service is
unavailable, excessively expensive, or unable to meet required reliability. Applications include law
enforcement, emergency preparedness, supporting the National air space system, military command and
control networks, and control links for various power, land, water, and electric-power management
systems. Other specified fixed links include video relay, data relay, and timing distribution signals

Probably the most critical system in the band is the USAF Space Ground Link Subsystem (SGLS). This
system, via Earth-to-space uplinks in the 1761-1842 MHz band, controls the U.S. military satellites,
including telecommunications satellites, intelligence gathering satellites, the Global Positioning System
(GPS) satellite constellation, and satellites of other Government agencies and U.S. allies. These satellites
provide space-based capabilities that are critical to the execution of all US military operations. The
satellites already in use that are associated with SGLS are not capable of being modified to operate to
accommodate another frequency and would have to be replaced by new satellites. SGLS operations must
continue to control these on-orbit assets for the duration of their life spans; which for some may extend
beyond 2017.

Air Combat Training (ACT) systems are also used extensively in this band segment. ACT systems are
more complex by the nature of their operations, as both fixed and aeronautical mobile equipment are
used. Air Force and Navy operate ACT systems. The DoD has stressed that training support systems such
as these are key elements in the military's effort to provide realistic simulation and combat preparedness
for pilot training in a peacetime environment.

Fixed links are operated by federal agencies for voice, data, and/or video communications where
commercial service is unuseable. Applications include law enforcement, emergency preparedness,
support for the National air space system, military command and control networks, and control links for
various power, land, water, and electric-power management systems. Other specified fixed links include
video relay, data relay, and timing distribution signals.



                                                   A-18
The Mobile Subscriber Equipment is a multi-band, tactical line-of-sight microwave radio system, more
accurately described as a "system-of-systems", because it is composed of several components which are
fully operational systems. The individual components that make up the Mobile Subscriber Equipment are
dependent upon several portions of the radio frequency spectrum (e.g., 30-88 MHz, 225-400 MHz, 1350-
1850 MHz, and 14.5-15.35 GHz). The inability of any of these components to operate successfully would
result in the failure of the overall Mobile Subscriber Equipment "system". One critical component of
Mobile Subscriber Equipment, the AN/GRC-226(V)2 Radio, is dependent on the 1755-1850 MHz band.
It is used to connect Radio Access Units (RAU) in the AN/TRC-190 series, to the Node Center Switch
(AN/TTC-47) of the network. Operational use plans call for 465 units per Army Corps, giving a total of
2,325 units for 5 Corps.

6. 1850-1990 MHz Band (present PCS bands). RR S5.388, which was adopted at WRC-92, states that
the band 1885-2025 MHz is intended for use, on a worldwide basis, by administrations wishing to
implement IMT-2000, and that such use does not preclude the use of the band by other services to which
it is allocated. In the United States the band 1850 - 1990 MHz is allocated for the Personal
Communications Service (PCS). The Commission's planned Notice of Proposed Rule Making is expected
to consider the extent to which the PCS may meet the demand for 3G services. The 1990 - 2025 MHz
band was recently reallocated for mobile satellite services that are expected to partly satisfy the satellite
component of 3G services.

7. 2110-2150 MHz Band. RR S5.388, which was adopted at WRC-92, states that the band 2110-2200
MHz is intended for use, on a worldwide basis, by administrations wishing to implement IMT-2000, and
that such use does not preclude the use of the band by other services to which it is allocated.
Domestically, the FCC has identified the 2110-2200 MHz band for reallocation from the fixed service for
new emerging technologies. The 2165-2200 MHz segment of this band was recently reallocated for the
mobile satellite service. BBA-97 requires reallocation of the 2110-2150 MHz band and assignment by
competitive bidding by September 30, 2002.

8. 2500-2690 MHz Band. The two major services in the 2500-2690 MHz band are the Multichannel
Multipoint Distribution System (MDS), and the Instructional Television Fixed Service (ITFS). There are
currently thirty-three 6 MHz channels, or 198 MHz of spectrum, allocated to MDS and ITFS. MDS
utilizes two channels in the 2150 to 2160 MHz band. MDS and ITFS share spectrum in the 2500 to 2686
MHz band.

MDS licensees transmit programming from one or more fixed stations, which is received by multiple
receivers at various locations. Nation-wide, there are over 2500 licenses for MDS in the band. Licenses
are granted on an area-wide basis, utilizing Basic Trading Areas. Formerly, MDS licensees used their
channels to provide a multichannel video programming service, so-called "wireless cable."
Approximately one million homes currently receive multichannel video programming service from
MDS/ITFS-based wireless cable systems. However, the MDS frequencies, located in the 2.1 and 2.5-2.7
GHz bands, also are suited for the high-speed, high-capacity delivery of broadband access to data, voice
and Internet service. The primary current and future uses of MDS will be to deliver this access. Rather
than being hardwired like the local telephone companies and local cable systems, MDS uses microwave
frequencies. Like broadcast television, MDS is transmitted from a broadcast tower, usually located on a
mountain or tall building, to special antennas on residences or businesses throughout a local market. In
the two-way environment, system configurations will be based on a "cellularized" plan, using series of




                                                   A-19
hub and booster stations to link various main stations to individual subscribers and to relay transmissions
throughout the system.


The other major service in the band is the ITFS, which is regulated under Part 74, Subpart I of the
Commission's Rules. ITFS channels are from 2500 to 2596 MHz, and interleaved with MDS channels
above 2644 MHz. Of the 31, six-megahertz channels in the MDS/ITFS spectrum band, the FCC licenses
twenty of these channels to non-profit educational entities. ITFS stations are currently utilized for a wide
variety of educational services by schools, hospitals and other educational facilities. In addition, ITFS
unused channels can be used for the same kind of broadband services discussed above and excess
capacity on those channels may be leased to MDS operators. Partnerships have developed between ITFS
spectrum holders and MDS companies that provide expertise, revenue, and access to hardware and
software to ITFS partners, to better enable them to build their distance learning programs.

In the last two years, the spectrum has undergone significant changes. In September 1998, the FCC
amended its rules to facilitate the provision of two-way communication services by MDS and ITFS
licensees. When MDS is used for two-way service, it becomes a viable broadband service delivery
option. Implemented two-way systems can provide advanced, ultra-high speed, high-capacity broadband
data and Internet services to households and business subscribers, as well as voice service to households
in competition with local exchange carriers. The new rules still contemplate fixed service, even for two-
way operations. The initial filing window for two-way service occurred from August 14, 2000 until
August 18, 2000 and approximately 3,000 applications were received.




                                                   A-20
INTERIM REPORT
3G SPECTRUM STUDY
2500-2690 MHz BAND




                     APPENDICES

                        FOR

                     SECTION 2.0




                         A-21
                                                   APPENDIX 2.1

                        Table 2-A: Characteristics of IMT-2000 Mobile Stations1

                                                                                     UWC-136
                                                                                     (TDMA)
                                                                          UWC-136      GPRS/
            Parameter                 CDMA-2000        CDMA-2000          (TDMA)       EDGE      W-CDMA
Carrier Spacing                        1.25 MHz         3.75 MHz           30 kHz     200 kHz     5 MHz
Transmitter Power                       100 mW           100 mW           100 mW     100 mW       100mW
Antenna Gain                             0 dBi            0 dBi             0 dBi      0 dBi       0 dBi
Antenna Height                           1.5 m            1.5 m             1.5 m      1.5 m       1.5 m
Body Loss                                 0 dB             0 dB             0 dB        0 dB       0 dBi

Access Techniques                        CDMA             CDMA             TDMA       TDMA         CDMA
Data Rates Supported                    144 kbps         384 kbps          30 kbps   384 kbps     384 kbps
                                                                           44 kbps
Modulation Type                       QPSK/BPSK        QPSK/BPSK         /4-DQPSK    GMSK         QPSK
                                                                            8-PSK     8-PSK
Emission Bandwidth
-3 dB                                   1.1 MHz          3.3 MHzf        0.03 MHz    0.18 MHz      3 GPP
-20 dB                                  1.4 MHz          4.2 MHz         0.03 MHz    0.22 MHz     TS25.101
-60 dB                                  1.5 MHz          4.5 MHz         0.04 MHz    0.24 MHz
Receiver Noise Figure                     9 dB             9 dB             9 dB        9 dB         9 dB
Receiver Thermal Noise Level           -113. dBma       -109 dBma        -121 dBma   -113 dBma   -109 dBm in
                                       -105 dBmb        -100 dBmb                                  384 kbps
Receiver Bandwidth
-3 dB                                   1.10 MHz         3.30 MHz         0.03 MHz   0.18 MHz         ?
-20 dB                                   1.6 MHz          4.7 MHz         0.04 MHz   0.25 MHz         ?
-60 dB                                   3.7 MHz          11 MHz          0.09 MHz   0.58 MHz         ?
Eb/No for Pe = 10-3                       6.6 dB           6.6 dB           7.8 dB     8.4 dB      3.1 dBg
Receiver Sensitivityc                   -107 dBm         -103dBm          -113 dBm   -104 dBm     -106 dBm
Interference Threshold 1d               -119 dBm         -115 dBm         -127 dBm   -119 dBm    Not Needed
Interference Threshold 2e               -104 dBm         -100dBm          -111dBm    -103dBm     Not Needed

a
  In bandwidth equal to data rate
b
  In receiver bandwidth
c
  For a 10-3 raw bit error rate, theoretical Eb/No
d
  Desired signal at sensitivity, I/N = -6 dB for a 10 percent loss in range
e
  Desired signal 10 dB above sensitivity, S/(I+N) for a 10-3 BER
f
  Shaded values were estimated.
g
  Assumes Eb/No for Pe = 10E-6 without diversity




1
  Extracted from “Key Characteristics for the International Mobile Telecommunications – 2000 (IMT-2000) Radio
Interfaces,” Recommendation ITU-R M.1455 (2000), International Telecommunication Union, and “Detailed
Specification of the Radio Interfaces of International Mobile Telecommunications – 2000,” Recommendation ITU-
R M.1457 (2000), International Telecommunication Union.




                                                         A-22
                      Table 2-B: Characteristics of IMT-2000 Base Stations2

                                                                                      UWC-136
                                                                       UWC-136         (TDMA)
            Parameter                CDMA-2000       CDMA-2000          (TDMA)       GPRS/EDGE      W-CDMA
Operating Bandwidth                   1.25 MHz         3.75 MHz          30 kHz        200 kHz        5 MHz
Transmitter Power                        10 W            10 W             10 W           10 W          10 W
Antenna Gain                          17 dBi per      17 dBi per       17 dBi per     17 dBi per    17 dBi per
                                      120o sector     120o Sector     120o sector     120o sector   120o sector
Antenna Height                           40 m             40 m            40 m           40 m          40 m
Tilt of Antenna                       2.5o down        2.5o down       2.5o down      2.5o down     2.5o down
Access Techniques                       CDMA            CDMA             TDMA           TDMA          CDMA
Data Rates Supported                   144 kbps        384 kbps          30 kbps                     384 kbps
                                                                         44 kbps      384 kbps
Modulation Type                      QPSK/BPSK       QPSK/BPSK        /4-DQPSK        GMSK           QPSK
                                                                         8-PSK         8-PSK
Emission Bandwidth
-3 dB                                  1.1 MHz         3.3 MHzf        0.03 MHz       0.18 MHz        3 GPP
-20 dB                                 1.4 MHz         4.2 MHz         0.03 MHz       0.22 MHz       TS25.104
-60 dB                                 1.5 MHz         4.5 MHz         0.04 MHz       0.24 MHz
Receiver Noise Figure                    5 dB            5 dB             5 dB           5 dB           5 dB
Receiver Thermal Noise Level          -117dBma        -113 dBma        -125 dBma      -117 dBma     -113 dBm in
                                      -109dBmb        -104 dBmb                                       384 kbps
Receiver Bandwidth
-3 dB                                     1.10 MHz        3.3 MHz         0.03 MHz    0.18 MHz           ?
-20 dB                                    1.67 MHz        4.7 MHz         0.04 MHz    0.25 MHz           ?
-60 dB                                     3.7 MHz         11 MHz         0.09 MHz    0.58 MHz           ?
Eb/No for Pe = 10-3                         6.6 dB          6.6 dB          7.8 dB      8.4 dB        3.4 dBg
Receiver Sensitivityc                     -111 dBm       -107 dBm         -117 dBm     -108.Bm       -110 dBm
Interference Threshold 1d                 -123dBm         -119dBm         -131 dBm    -123 dBm      Not Needed
Interference Threshold 2e                 -108 dBm       -104 dBm         -115 dBm    -107dBm       Not Needed
a
  In bandwidth equal to data rate
b
  In receiver bandwidth
c
  For a 10-3 raw bit error rate, theoretical Eb/No
d
  Desired signal at sensitivity, I/N = -6 dB for a 10 percent loss in range
e
  Desired signal 10 dB above sensitivity, S/(I+N) for a 10 -3 BER
f
  Shaded values were estimated.
g
  Assumes Eb/No for Pe = 10E-6 without diversity




2
  Extracted from “Key Characteristics for the International Mobile Telecommunications – 2000 (IMT-2000) Radio
Interfaces,” Recommendation ITU-R M.1455 (2000), International Telecommunication Union, and “Detailed
Specification of the Radio Interfaces of International Mobile Telecommunications – 2000,” Recommendation ITU-
R M.1457 (2000), International Telecommunication Union.




                                                       A-23
                                                                                          3
                            Table 2-C: IMT-2000 Traffic Model Characteristicsa

                           Parameter                                               Value
                      Traffic Environments                                          Rural
                                                                                  Vehicular
                                                                                 Pedestrian
                                                                   In-building (Central business district)
                      Maximum Data Rates                                      Rural - 9.6 kbps
                                                                           Vehicular - 144 kbps
                                                                           Pedestrian - 384 kbps
                                                                           In-building - 2 Mbps
                            Cell Size                                       Rural - 10 km radius
                                                                        Vehicular - 1000 m radius
                                                                         Pedestrian - 315 m radius
                                                                         In-building - 40 m radius
                 Users per cell during busy hour                           Rural - not significant
                                                                              Vehicular - 4700
                                                                             Pedestrian - 42300
                                                                             In-building - 1275
       Percent of total uplink traffic >64 kbps during busy                Rural - not significant
                                hour                                          Vehicular - 34%
                                                                              Pedestrian - 30%
                                                                             In-building - 28%
        Percent of total downlink traffic >64 kbps during                  Rural - not significant
                            busy hour                                         Vehicular - 78%
                                                                              Pedestrian - 74%
                                                                             In-building - 73%
        Average number of users per cell per MHz during                    Rural - not significant
         busy hour assuming frequency duplex operation                            Vehicular
                                                                               < 64 kbps - 16
                                                                                > 64 kbps - 4
                                                                                 Pedestrian
                                                                              < 64 kbps - 150
                                                                               > 64 kbps - 64
                                                                                 In-building
                                                                                < 64 kbps - 4
                                                                                > 64 kbps - 2

a
    Values in the table are for a mature network.




3
 Extracted in part from “Spectrum Requirements for International Mobile Telecommunications – 2000 (IMT-
2000),” Report ITU-R M.2023 (2000), International Telecommunications Union.




                                                            A-24
                                                 APPENDIX 2.2

              INTERNATIONAL USE OF 1710-1885 AND 2500 – 2690 MHZ BANDS

                             [Charts Reproduced from Report ITU-R M.2024]4


                                   Current and Planned Utilization
                                    Terrestrial Component Bands

                                       1 710-1 785/1 805-1 885 MHz
                *
          CEPT              1 710-1 785/1 805-1 880 MHz: This band is also used in Europe for second
                            generation mobile (GSM 1800). Availability of this band for IMT-2000 can only
                            be made progressively in the longer term as current usage of the band decreases.
                            The timetable availability of this band for IMT-2000 may differ on national basis.
                            On this basis, this band as a whole is also considered by CEPT to be a candidate for
                            IMT-2000 expansion.
                            1 880-1 885 MHz: This band in Europe currently forms the lower part of the DECT
                            band. The upper part of the DECT band (1 885–1 900 MHz) is already identified
                            for IMT-2000.
                            The band 1 880–1 885 MHz is considered by CEPT as a candidate for IMT2000
                            expansion. The whole of the [Digital Enhanced Cordless Telecommunications]
                            DECT band (1 880–1 900 MHz) can only be made available for IMT-2000 in the
                            longer term however as DECT usage decreases.
          U.S.A             1 710-1 755 MHz – reallocated for mixed (government/non-government use after
                            Jan. 1999) available for commercial use Jan. 2004. This band may be suitable for
                            IMT-2000.
                            1 805-1 850 MHz – Satellite Ground Link System (SGLS). Exclusive government
                            allocation. Not suitable or available for IMT-2000
                            1 755-1 805 MHz – Exclusive government allocations to FIXED, MOBILE and in
                            parts of the band SPACE OPERATIONS. Not suitable or available for IMT-2000.
                            1 850-1 910/1 930-1 990 MHz: US PCS Band. Suitable for IMT-2000 as pre-
                            IMT-2000 services evolve to IMT-2000.
                            1 910-1 930 MHz: Unlicensed Low-Power PCS. May be suitable for low power
                            IMT-2000 applications as pre-IMT-2000 services evolve to IMT-2000.
         Malaysia           DCS 1800
                            1 880-1 900 MHz DECT (FOR INDOOR USE ONLY)
          Korea             These bands were assigned for land mobile service(using CDMA system)




4
 “Summary of Spectrum Usage Survey Results,” Report ITU-R M.2024 (2000), International Telecommunication
Union.

* Agreed and developed within European Radiocommunications Committee Task Group 1 of the Conférence
Européenne des Administrations des Postes et des Télécommunications (CEPT ERC TG1).




                                                    A-25
   China       1 710-1 755/1 805-1 850 MHz: cellular system
               1 880-1 900/1 960-1 980 MHz: Wireless access system of FDD mode
               1 900-1 920 MHz: Wireless access systems of TDD mode
   Japan       These bands were assigned for FIXED, MOBILE, SPACE RESERCH, and SPACE
               OPERATION service
  Canada       1 710-1 850 MHz: In Canada, this band is used for low capacity fixed systems
               Canada‟s view is that fixed systems can be phased out at an appropriate time and
               this band has been identified by Canada as a candidate for IMT-2000.
               1 850-1 885 MHz: This band forms part of the frequency range referred to as the
               PCS Band Plan and has also been identified as a candidate for ITM-2000.
 Australia     Fixed/mobile: in extensive use

South Africa   1 710-1785/1 805-1 880 MHz         DCS 1800
               1 880-1 900 MHz                    DECT
               1 900-1 920 MHz                    Extended DECT
               1 885-2 025/2 110-2 200 MHz        (WARC-92) reserved for FPLMTS/UMTS
                                                  reserved for satellite       component     of
               1 980-2 010/2 170-2 200 MHz        FPLMTS/UMTS
   Brazil      1 710–1 850 MHz                    In Brazil, this band is used for low capacity
                                                  fixed systems. Parts of this band might be
                                                  suitable for IMT-2000.
               1 850–1 885 MHz                    In Brazil, this band is used for low capacity
                                                  fixed systems. It forms part of the frequency
                                                  range referred to as the PCS Band Plan,
                                                  although Brazil has not implemented it.
                                                  The bands 1 850-1 870/1 930-1 950 MHz are
                                                  planned for introduction of Fixed Wireless
                                                  Access systems.
                                                  Parts of this band might be suitable for
                                                  IMT-2000.
New Zealand    1 706.5-1 880/ MHz                 FS,   Potentially suitable and available for
                                                  IMT-2000 extension
               1 880-1 920 MHz                    FS,    PHS, DECT Potentially suitable but
                                                  unavailable   for     IMT-2000 extension;
                                                  clearance may be difficult




                                      A-26
                        Current and Planned Utilization
                         Terrestrial Component Bands

                                  2 500-2 690 MHz
  CEPT*        This band is considered by CEPT as a prime candidate band for IMT-2000
               expansion after phasing out of existing usage (fixed and ENG/OB). Geographical
               sharing (urban/rural) is one solution to facilitate the transition, or where sharing
               between services in the longer term is required.
   U.S.A       Multipoint Distribution Service/Instructional Television Fixed Service, point to
               multipoint video links to homes, schools and businesses. Two way response use as
               well. This band is also assigned to the Broadcast Satellite Service. Coordination of
               the BSS service with additional satellite and terrestrial systems would be difficult.
               This band is currently not available for IMT-2000, however some licensees may
               choose to evolve to technologies and services, such as IMT-2000.
 Malaysia      MMDS Application

   Korea

   Japan       This band is used for mobile satellite system and was assigned Broadcasting Satellite
               service.
   China       2 535-2 599 MHz : Multiple Microwave Distribute System (MMDS) of cable TV
               transmission system
               Broadcasting-satellite service (audio).
  Canada       This band has been identified for use for multipoint communications service
               (2 500-2 596 MHz) and multipoint distribution service (Broadcasting)
               (2 596-2 686 MHz. Canada has extensive licensing activity for MCS and MDS
               underway in this band. No other types of radio systems are currently being licensed
               in this range.
 Australia     2450 – 2690 MHz Electronic News Gathering (ENG)

South Africa   2 690-2 700 MHz                       MMDS / FS Radio Astronomy
               2 520-2 593/2 597-2 670 MHz           FS
   Brazil      2 500-2 690 MHz                       This band is used for multichannel multipoint
                                                     distribution service. At this time Brazil is
                                                     concluding an extensive licensing activity for
                                                     MMDS in this band. No other types of radio
                                                     systems are currently being licensed in this
                                                     range. Not suitable for IMT-2000.
New Zealand    2 498.5-2 690 MHz                     FS, used extensively for ENG/OB. Suitable for
                                                     IMT-2000 extension, but currently unavailable
                                                     due to extensive ENG/OB applications.




                                         A-27
                        Current and Planned Utilization
                             Satellite component

                           2 500-2 520/2 670-2 690 MHz
  CEPT*        This frequency band could be made available for IMT-2000 in Europe, pending
               market demand.
   U.S.A       Multipoint Distribution Service/Instructional Television Fixed Service, point to
               multipoint video links to homes, schools and businesses. Two way response use as
               well. Not suitable for IMT-2000.
               Not allocated to MSS on a worldwide basis until 2005.
 Malaysia      Frequencies have been filed by MEASAT for LEO/MEO use.

   Korea       These bands were allocated for mobile satellite service at WARC-92. Any assignment
               for these bands is reserved until specific plans in Korea
   China       Space Service

   Japan       These bands are extensively used for Mobile-Satellite systems.

  Canada       These bands have been identified for terrestrial services.

 Australia     Current Australian usage of these bands would make usage by MSS in Australia
               difficult.
South Africa

   Brazil      These bands are used for multichannel multipoint distribution service. At this time
               Brazil is concluding an extensive licensing activity for MMDS in these bands. No
               other types of radio systems are currently being licensed in this range. Not suitable for
               IMT-2000.
New Zealand




                                         A-28
                                   Current and Planned Utilization
                                        Satellite component

                                       2 520-2 535/2 655-2 670 MHz
              *
        CEPT              These bands have been identified as possible candidate bands for the terrestrial
                          component of IMT-2000, and are therefore not identified as suitable for satellite
                          component. However, it is envisaged that these bands may be used for MSS in some
                          areas, where the demand for satellite services is high.
         U.S.A            2 520-2 655 MHz:
                          Multipoint Distribution Service/Instructional Television Fixed Service, point to
                          multipoint video links to homes, schools and businesses. Two way response use as
                          well. This band is currently not available for IMT-2000, however some licensees may
                          choose to evolve to technologies and services, such as IMT-2000.
                          2 655-2 670 MHz:
                          Multipoint Distribution Service/Instructional Television Fixed Service, point to
                          multipoint video links to homes, schools and businesses. Two way response use as
                          well. Also used for Radio Astronomy. This band is currently not available for IMT-
                          2000, however some licensees may choose to evolve to technologies and services,
                          such as IMT-2000.
       Malaysia           Available

         Korea            These bands were allocated for mobile satellite service at WARC-92. Any assignment
                          for these bands is reserved until specific plans in Korea.
         China            Space service

         Japan            These bands are extensively used for Mobile-Satellite systems.

        Canada            Currently identified for terrestrial services.

       Australia          Current Australian usage of these bands would make usage by MSS in Australia
                          difficult.
      South Africa

         Brazil           These bands are used for multichannel multipoint distribution service. At this time
                          Brazil is concluding an extensive licensing activity for MMDS in these bands. No
                          other types of radio systems are currently being licensed in this range. Not suitable for
                          IMT-2000.




*
 Agreed and developed within European Radiocommunications Committee Task Group 1 of the Conférence
Européenne des Administrations des Postes et des Télécommunications (CEPT ERC TG1).




                                                      A-29
                                                    APPENDIX 2.3

                                           IMT-2000 Spectrum Plans By Country5
                        (Italics denote that the country has completed the licensing process)
            Country         Frequency        Amount         of   Licenses   Spectrum per License      License Award
                            Bands            Spectrum            Issued                               Date
            Austria         TBD              145 MHz             4-6        12 frequency              Q1 2001
                                                                            packages of 2x5
                                                                            MHz
                                                                            5 packages of 1x5 MHz
            Australia       1885-2025 MHz    140 MHz             TBD        TBD                       Dec. 2000
                            2110-2200 MHz    (2x60 MHz paired               (may be different based
                                             20 MHz unpaired)               on region)
            Belgium         1900-1920 MHz    155 MHz             4                                    Q4 2000
                            1920-1980 MHz
                            2010-2025 MHz
                            2110-2170 MHz
            Brazil                                               9                                    3 in Q4 2000
                                                                                                      6 in 2001
            Czech           1900-1920 MHz    TBD                 3          3 National licenses of    TBD
            Republic        1920-1980 MHz                                   2 x 10-15 MHz
                            2010-2025 MHz                                   + 5 MHz
                            2110-2170 MHz
            China           TBD                                  4                                    Sept. 2001
            Denmark         1900-1980 MHz    155 MHz             4                                    Q4 2001
                            2010-2025 MHz
                            2110-2170 MHz
            Finland         1900-1920 MHz,   140 MHz             4          4 licenses of 2 x 15      March 1999
                            1920-1980 MHz                                   MHz + 5 MHz
                            2010-2025 MHz,
                            2110-2170 MHz
            France                           140 MHz             4                                    Q1 2001
            Germany         1900-1920 MHz,   145 MHz             6          Each            license   Aug. 2000
                            1920-1980 MHz,                                  encompasses 2 slices of
                            2010-2025 MHz,                                  2x5 MHz (2x10 MHz
                            2110-2170 MHz                                   each)
            Hong Kong       1885-1920 MHz    170 MHz             4                                    4Q 2000
                            1920-1980 MHz
                            2010-2025 MHz
                            2110-2170 MHz
            Ireland         1900-1920 MHz    155 MHz             4                                    Q2 2001
                            1920-1980 MHz
                            2010-2025 MHz
                            2110-2170 MHz
            India                                                TBD                                  TBD
            Israel          TBD but within   175 MHz             TBD                                  TBD
                            1700-2200 MHz
            Italy                            125 MHz             5          5 licenses of 2x10 MHz    Nov. 2000
                                                                            + 5 MHz
            Japan                                                3                                    June 2000
            South Korea                                          3                                    Q4 2000
            Latvia                                               TBD                                  Q4 2000


            Netherlands                      145 MHz             5          3 licenses of     July 2000
                                                                            (2x10MHz + 5 MHz)

5
    Developed from publically available sources. Believed to be accurate as of mid-September 2000.




                                                           A-30
          Country        Frequency        Amount             of   Licenses   Spectrum per License       License Award
                         Bands            Spectrum                Issued                                Date
                                                                             and 2 licenses of
                                                                             (2x15MHz)

          Malaysia                                                4                                     July 2000
          New Zealand    1920-1980 MHz    140 MHz                 5          5 licenses of up to 2x15   Q4 2000
                         2010-2025 MHz    (one 2x15 MHz                      MHz + 5 MHz
                         2110-2170 MHz    license is reserved
                                          for Maori trust)
          Norway                          140 MHz                 4                                     Q4 2000
          Poland                                                  4-5                                   Q1 2001
          Portugal       1900-1920 MHz    140 MHz                 4                                     Q1 2001
                         1920-1980 MHz
                         2110-2170 MHz
          Russia                                                  TBD                                   Q2 2001
          Singapore                                               4-6                                   Q4 2000
          Slovenia                                                3                                     Q4 2000
          South Africa                                            3                                     Q2 2001
          Spain          1920-1980 MHz    140 MHz                 4          4 licenses of 2x15 MHz     March 2000
                         2010-2025 MHz                                       + 5 MHz
                         2110-2170 MHz
          Sweden         1900-1920 MHz    140 MHz                 4          4 National licenses of     Q4 2000
                         1920-1980 MHz                                       2x15 MHz + 5 MHz
                         2010-2025 MHz
                         2110-2170 MHz
          Switzerland    1900-1920 MHz    95 MHz (1/1/02)         4                                     Q4 2000
                         1920-1980 MHz    140 MHz (1/1/06)
                         2010-2025 MHz
                         2110-2170 MHz
          Taiwan         TBD                                      Up to 5                               Q1 2001
          United         1900-1920 MHz,   140 MHz                 5          1 license of 2x15 MHz      April 2000
          Kingdom        1920-1980 MHz,                                      + 5 MHz, 1 license of
                         2010-2025 MHz,                                      2x15 MHz, and 3
                         2110-2170 MHz                                       licenses of 2x10 MHz +
                                                                             5 MHz



Sources for Data in Appendix 2.3

3rd Generation, CELLULAR NEWS, available at http://www.cellular-news.com/3G/index.htm (visited Aug. 21, 2000);
3G Wireless Licensing Process in Europe, TIA Europe, (Aug. 2000), available at
http://www.tiaonline.org/international/regional/nis/europconnect-aug00.pdf (visited Aug. 21, 2000); Fifth Annual
Report and Analysis of Competitive Market Conditions With Respect to Commercial Mobile Services, FCC 00-289
(rel. Aug. 18, 2000), available at http://www.fcc.gov/wtb/reports/fcc00289.doc (visited Aug. 21, 2000); William
Boston, Germany's Wireless Bids Beat Forecasts: License Auction Reaches $11.43 Billion as Firms Crave the Big
Market, THE WALL STREET JOURNAL (Aug. 9, 2000); Telecommunications Industry Association, Europe Prepares
for 3G, available at http://pulse.tiaonline.org/0300/text/euro3g.htm (visited, Aug. 21, 2000); Edmund L. Andrews,
Costly Auction For German Phone Rights, NEW YORK TIMES (Aug. 19, 2000); France Outlines 3G license Award
Process, MOBILE & SATELLITE (Aug. 18, 2000); IMT-2000, Ericsson, available at
http://www.ericsson.se/KR/english/imt2000/Licensing.htm (visited, Aug. 21, 2000); Asia-Pacific: Australia Faces
3G Hurdles, ROAM, (May, 2000), available at http://www.totaltele.com/roam/news11.asp; Kenneth Neil Cukier,
France's 3G Beauty Contest Looks Ugly All Around, RED HERRING, (June 8, 2000)
http://www.redherring.com/insider/2000/0608/tech-france3g060800.html (visited Aug. 21, 2000); Korean Gov't to
Pick Three License Recipients for IMT-2000 Services, ASIZBIZTECH,
http://www.nikkeibp.asiabiztech.com/wcs/leaf?CID=onair/asabt/news/106104 (visited, Aug. 21, 2000); Kim Griggs,
Yet Another Delay in New Zealand?, WIRED, available at
http://www.wired.com/news/business/0,1367,37268,00.html, visited (Aug. 21, 2000); 3G Licensing, Nokia, available



                                                         A-31
at http://www.nokia.com/3g/licensing_upcoming#licences (visited Aug. 21, 2000); Radio Spectrum Auction Pages,
[New Zealand] Ministry of Economic Development, available at http://auction.med.govt.nz/ (visited Aug. 21, 2000);
Italy Confirms 3G Awards Process, CELLULAR NEWS (June 22, 2000), available at http://www.cellular-
news.com/2000/06_24_2000.htm (visited Aug. 21, 2000); Russia to Offer 3G Licenses in 2001, CELLULAR NEWS
(June 16, 2000), available at http://www.cellular-news.com/2000/06_17_2000.htm (visited Aug. 21, 2000); Slovenia
to Open Tender for 3 UMTS Licenses, TOTAL TELECOM (Aug. 17, 2000), available at
http://www.totaltele.com/view.asp?ArticleID=30001&pub=tt&categoryid=625; Brazil Decision Opens GSM
Floodgates, GLOBAL MOBILE 4 (July 19, 2000); Global Roundup of Mobile License Bids and Bidders, GLOBAL
MOBILE 11 (Aug. 2, 2000); UMTS: Einführung von Mobilfunk der dritten Generation in der Schweiz (April 1999),
available at http://www.bakom.ch/ger/subsubpage/docs/688/688.pdf (visited Aug. 28, 2000); Public Digital 3rd
Generation Mobile Networks, available at http://www.tst.dk/index_uk.htm (visited Aug. 28, 2000); Tentative Band
Plan for IMT-2000, RSAC Paper 3/2000, available at http://www.ofta.gov.hk/index_eng.html (visited Aug. 28,
2000); Consulta Pública Sobre La Competencia En El Mercado De Los Servicios De Telefonía Móvil Disponible Al
Público, available at http://www.cmt.es/cmt/centro_info/c_publica/index.htm (visited Aug. 29, 2000); L‟Institut
Belge Des Services Postaux Et Des Télécommunications, Plan des Fréquences, available at
http://www.bipt.be/Pages/French/Telecoms/GestFreq/PlanFreq.htm (visited Sept. 1, 2000); Office of the Director of
Telecommunications Regulation [Ireland], Extending Choice: Opening the Market for Third Generation Mobile
Services (3G Mobile), Consultation Paper, available at http://www.odtr.ie/docs/odtr0052.doc (visited Sept. 1, 2000);
ICP [Portugal] Opens Public Tender for UMTS licenses, Press Release, available at
http://www.icp.pt/press/1999/not241uk.html (visited Sept. 5, 2000); Frequency allocation in the 900 MHz, 1800
MHz and 2 GHz bands, Post- och Telestyrelsen, (PTS), available at
http://www.pts.se/generic_eng.asp?avdelning=generic
_eng&uavdelning=generic_eng&u2avdelning=Tools%20for%20applicants1&lang=&header=Tools%20for%20appli
cants (visited Sept. 5, 2000); Neal Sandler, Israel to Issue 3G Tenders in October, TOTAL TELECOM, available at
<http://www.totaltele.com/view.asp?ArticleID=31416&pub=tt&categoryid=625> (visited Sept. 14, 2000).




                                                       A-32
INTERIM REPORT
3G SPECTRUM STUDY
2500-2690 MHz BAND




                     APPENDICES

                        FOR

                     SECTION 3




                        A-33
                                                                                APPENDIX 3.1

2483.5-2500                   2483.5-2500                    2483.5-2500                    2483.5-2500               2483.5-2500
FIXED                         FIXED                          FIXED                          MOBILE-SATELLITE          MOBILE-SATELLITE          ISM Equipment (18)
MOBILE                        MOBILE                         MOBILE                          (space-to-Earth) US319    (space-to-Earth) US319   Satellite
MOBILE-SATELLITE              MOBILE-SATELLITE               MOBILE-SATELLITE               RADIODETERMINATION-       RADIODETERMINATION-        Communications (25)
 (space-to-Earth)              (space-to-Earth)               (space-to-Earth)               SATELLITE (space-to-      SATELLITE (space-to-     Private Land
Radiolocation                 RADIOLOCATION                  RADIOLOCATION                   Earth) S5.398             Earth) S5.398            Mobile (90)
                              RADIODETERMINATION-            Radiodetermination-satellite                                                       Fixed Microwave (101)
                               SATELLITE (space-to-           (space-to-Earth) S5.398
S5.150 S5.371 S5.397 S5.398    Earth) S5.398
S5.399 S5.400 S5.402
                              S5.150 S5.402                  S5.150 S5.400 S5.402           S5.150 753F US41          S5.150 753F US41 NG147
2500-2520                     2500-2520                                                     2500-2655                 2500-2655
FIXED S5.409 S5.410           FIXED S5.409 S5.411                                                                     FIXED S5.409 S5.411       Domestic Public Fixed
 S5.411                       FIXED-SATELLITE (space-to-Earth) S5.415                                                 US205                     (21)
MOBILE except aeronautical    MOBILE except aeronautical mobile                                                       FIXED-SATELLITE           Auxiliary Broadcasting
 mobile                       MOBILE-SATELLITE (space-to-Earth) S5.403                                                (space-to-Earth) NG102    (74)
MOBILE-SATELLITE                                                                                                      BROADCASTING-
 (space-to-Earth) S5.403                                                                                              SATELLITE NG101

S5.405 S5.407 S5.408 S5.412
S5.414                        S5.404 S5.407 S5.414 S5.415A
2520-2655                     2520-2655                      2520-2535
FIXED S5.409 S5.410 S5.411    FIXED S5.409 S5.411            FIXED S5.409 S5.411
MOBILE except aeronautical    FIXED-SATELLITE                FIXED-SATELLITE
 mobile                        (space-to-Earth) S5.415        (space-to-Earth) S5.415
BROADCASTING-                 MOBILE except aeronautical     MOBILE except aeronautical
 SATELLITE S5.413 S5.416       mobile                         mobile
                              BROADCASTING-                  BROADCASTING-
                               SATELLITE S5.413 S5.416        SATELLITE S5.413 S5.416

                                                             S5.403 S5.415A
                                                             2535-2655
                                                             FIXED S5.409 S5.411
                                                             MOBILE except aeronautical
                                                              mobile
                                                             BROADCASTING-
S5.339 S5.403 S5.405 S5.408                                   SATELLITE S5.413 S5.416
S5.412 S5.417 S5.418
                              S5.339 S5.403                  S5.339 S5.418                  S5.339 US205 US269        S5.339 US269




                                                                                        A-34
                                                                             2655-3700 MHz (UHF/SHF)                                                                          Page

                                    International Table                                                            United States Table                     FCC Rule Part(s)
Region 1                      Region 2                       Region 3                      Federal Government                Non-Federal Government
2655-2670                     2655-2670                      2655-2670                     2655-2690                         2655-2690
FIXED S5.409 S5.410 S5.411    FIXED S5.409 S5.411            FIXED S5.409 S5.411           Earth exploration-satellite       FIXED US205 NG47
MOBILE except aeronautical    FIXED-SATELLITE                FIXED-SATELLITE                (passive)                        FIXED-SATELLITE
  mobile                       (Earth-to-space)               (Earth-to-space) S5.415      Radio astronomy                    (Earth-to-space) NG102
BROADCASTING-                  (space-to-Earth) S5.415       MOBILE except aeronautical    Space research (passive)          BROADCASTING-
  SATELLITE S5.413 S5.416     MOBILE except aeronautical      mobile                                                          SATELLITE NG101
Earth exploration-satellite   mobile                         BROADCASTING-                                                   Earth exploration-satellite
 (passive)                    BROADCASTING-                   SATELLITE S5.413 S5.416                                         (passive)
Radio astronomy                SATELLITE S5.413 S5.416       Earth exploration-satellite                                     Radio astronomy
Space research (passive)      Earth exploration-satellite     (passive)                                                      Space research (passive)
                               (passive)                     Radio astronomy
                              Radio astronomy                Space research (passive)
                              Space research (passive)
S5.149 S5.412 S5.417 S5.420
                              S5.149 S5.420                  S5.149 S5.420
2670-2690                     2670-2690                      2670-2690
FIXED S5.409 S5.410 S5.411    FIXED S5.409 S5.411            FIXED S5.409 S5.411
MOBILE except aeronautical    FIXED-SATELLITE (Earth-        FIXED-SATELLITE (Earth-
  mobile                        to-space) (space-to-Earth)     to-space) S5.415
MOBILE-SATELLITE               S5.415                        MOBILE except aeronautical
 (Earth-to-space)             MOBILE except aeronautical     mobile
Earth exploration-satellite   mobile                         MOBILE-SATELLITE
 (passive)                    MOBILE-SATELLITE                (Earth-to-space)             US205 US269                       US269
Radio astronomy                (Earth-to-space)              Earth exploration-satellite
Space research (passive)      Earth exploration-satellite    (passive)
                               (passive)                     Radio astronomy
                              Radio astronomy                Space research (passive)
                              Space research (passive)
                                                             S5.149 S5.419 S5.420
S5.149 S5.419 S5.420          S5.149 S5.419 S5.420           S5.420A
2690-2700                                                                                  2690-2700
EARTH EXPLORATION-SATELLITE (passive)                                                      EARTH EXPLORATION-SATELLITE (passive)
RADIO ASTRONOMY                                                                            RADIO ASTRONOMY US74
SPACE RESEARCH (passive)                                                                   SPACE RESEARCH (passive)
S5.340 S5.421 S5.422                                                                       US246
2700-2900                                                                                  2700-2900                         2700-2900
AERONAUTICAL RADIONAVIGATION S5.337                                                        AERONAUTICAL RADIO-
Radiolocation                                                                               NAVIGATION S5.337
                                                                                           METEOROLOGICAL AIDS
                                                                                           Radiolocation G2

S5.423 S5.424                                                                              S5.423 US18 G15                   S5.423 US18


                                                                                      A-35
A-36
                                           APPENDIX 3.2

DESCRIPTION OF TRADITIONAL ITFS USE

         The Clark County School District in Las Vegas, NV (“Clark County”). Clark County has
operated ITFS facilities to provide core educational programming to its students since 1968. As of 1997,
Clark County was the tenth largest school district in the country, with a student population of 186,000.
At that time, Clark County served 170 schools with ITFS programming. Over 80% of Clark County‟s
elementary school teachers reported using ITFS programming in the classroom each week, and 60% of
secondary teachers reported such use. In the 1996-1997 school year, Clark County distributed
approximately 240 hours per week of ITFS programming to more than 170 receive sites.

         Clark County uses its licensed ITFS spectrum to offer many unique educational courses and
supplemental learning programs. Over 75% of the Clark County‟s teachers certified to teach English as a
Second Language received their certification courses over ITFS from 1994-1997. In addition, due to a
shortage of certified foreign language teachers, 100% of mandatory elementary Spanish language
instruction in Clark County originates on ITFS. Furthermore, hundreds of at-risk children enrolled in,
and successfully completed, remedial Algebra, English and World History courses delivered, in part,
over ITFS. Latchkey children received homework assistance from certified teachers via an ITFS
distributed Homework Hotline program that received over 12,000 calls in the 1997 school year.
Moreover, Clark County, in cooperation with the local community college and university, has used ITFS
to offer over 20 dual high school/college credit courses for Clark County students. These programs
served hundreds of college bound students while reducing classroom overcrowding and improving
student/faculty ratios.

         Clark County has indicated that it plans to use its ITFS spectrum in the future to offer live
interactive French classes, additional math programming, expanded science courses, adult continuing
education courses, live and interactive professional development courses, expanded G.E.D. courses and
live, interactive support staff programs. In addition, Clark County plans on carrying certain
programming such as electronic field trips live instead of on a tape-delay basis.

        The Archdiocese of New York operates one of the nation‟s oldest and largest ITFS systems. The
Archdiocesan ITFS transmits broadcasts programs to over 52,000 students, and carries more than 150
courses each year at the elementary, secondary, inservice and adult education levels. In addition, one
channel is reserved for “Dial-A-Lesson,” permitting teachers to arrange for a particular program to be
aired on a date and time of their choice. The Archdiocese operates two fully equipped production studios
and offers students from area colleges and universities internships in video production.

          In addition, the Catholic Television Network (CTN) operates one of the most successful ITFS
programs throughout the country. CTN offers programs in all elementary and secondary school subject
areas, as well as teacher in-service training and programs for senior groups, disabled persons, and health
care agencies. Recent innovative ITFS distance learning programs offered by CTN have included: a
videoconference with a panel of professional writers in Los Angeles and New York; an electronic field
trip to the Smithsonian National Zoo to learn about a language project with orangutans, with students
given the opportunity to ask questions of zoo scientists by telephone or e-mail; and a program exploring
the inner workings of CNN News, allowing students meet the reporters, editors, and production staff.
Notably, CTN plans on utilizing two-way technology to enhance its distance learning programs. CTN
anticipates making interactive teleconferences more immediate by sending pictures, voice and data over
air waves rather than telephone wires and anticipates providing its own connection to the Internet. Other
typical ITFS educational systems include the following:


                                                  A-37
         Hampton Roads Educational Telecommunications Association. HRETA began
        in 1961 and has used ITFS technology for the past 15 years to deliver educational and
        public service information, including medical education to rural medical health
        facilities, televised college credit courses and educational programming service to 13
        area secondary school systems for use in the classroom and media centers.

         Miami-Dade County Public Schools. Miami-Dade County Public Schools, the
        fourth largest school district in the United States, uses its ITFS channels to serve over
        360,000 K - 12 students and over 140,000 adult students daily with over 10,000 hours
        of programming a year. The school district also utilizes its ITFS channels to train
        over 18,7000 teachers throughout the school system.

         Jefferson County Public Schools of Louisville, Kentucky. Jefferson County
        Public Schools of Louisville uses its ITFS system extensively, providing 160 hours of
        instructional programming per week to over 150 schools, in addition to four to six
        hours per week of professional development training.

         The Instructional Television Foundation. ITF is the licensee of seven stations
        located in Indianapolis, Philadelphia, Sacramento, Kansas City, Salt Lake City,
        Phoenix and Las Vegas. In Las Vegas, ITF transmits correctional facilities or
        alternative education sites that are unable to take advantage of conventional
        instructional resources.

         Network for Instructional TV, Inc. NITV holds licenses for 88 ITFS channels in
        22 cities, in 13 states and the District of Columbia. NITV serves over one million
        teachers and students daily.

         St. Lucie County School District. St. Lucie County School District in Florida
        utilizes its ITFS channels to enhance its curriculum in the areas of science, reading
        and mathematics. Further, ITFS and distance learning have been an important tool in
        integrating Discipline-Based Art Education (DBAE) for its students. Art training
        workshops are transmitted on ITFS channels. Moreover, art aesthetics, criticism,
        history and production of visual arts, music, dance and drama are brought to the
        schools and community through distance learning. Teachers also participate in timely
        professional development workshops over ITFS channels.

        In addition, Arizona State University offered 119 courses via ITFS in the year 2000. In addition,
the University offered 116 Internet courses, which could be sent over two-way systems in the future.
Enrollment in these courses delivered via these technologies totaled 4,679 students in 2000 and continues
to increase. In addition, the University of California, Santa Barbara ITFS system is currently offering
undergraduate course materials that compliment live courses in Anthropology, English, History, Law and
Society, Political Science, Psychology, and Sociology.

         California State University, Chico (“CSU, Chico”) has extensively used its ITFS spectrum to
help educate its students. CSU, Chico is located in rural Northern California, 99 miles north of the state
capital of Sacramento. In the late 1960‟s and into 1970, the California Coordinating Council of Higher


                                                   A-38
Education conducted a study on the needs of higher education in rural Northern California. A direct
result of this report was the creation of an extensive ITFS system throughout Northern California. In
1975, an ITFS/Microwave link was established between CSU, Chico and the University of California at
Davis (“UCD”), 92 miles south of Chico. The link was created to allow the Department of Computer
Science at UCD to use CSU, Chico computer science courses for UCD‟s developing doctoral program in
Computer Science.

         Throughout the years, the initial ITFS/Microwave system expanded to 16 sites throughout
Northern California. The most distant ITFS receive site was located in Yreka, 173 miles north of
campus. The eastern leg of the system extended 140 miles over the Sierra Nevada into the United States
Sierra Army Depot. The eastern link provided courses to residents in Grass Valley (90 miles from
campus), and the southwest leg extended 49 miles to Colusa. Each academic year 50 upper division
courses generated approximately 1200 enrollments at the learning sites throughout California. A variety
of bachelor‟s degrees, program minors and certificate programs were delivered via this system. The
courses were concurrently taught to regular on-campus students, and ITFS students paid the exact same
fees as if they were attending class live in Chico.

        Notably, CSU, Chico has delivered computer science courses, live via ITFS, to a Hewlett-
Packard division in Roseville, California since 1981. The University has also been very active in
producing various teleconferences for audiences in California and throughout the United States. Since
1985 CSU, Chico has produced and broadcast from this campus almost 100 teleconferences. One of the
University‟s first teleconferencing efforts was a program called Consider College, offered on October 8,
1985. This program, aimed at high school and community college students, parents and guidance
personnel, dealt with admissions requirements, financial aid processes, considerations regarding housing,
and special programs for community colleges.

         The University of Maryland is another example of a school successfully integrating ITFS into its
curriculum. The University of Maryland‟s Instructional Television System (ITV) has become an integral
part of the school, beaming its courses to classrooms located in Maryland, Virginia, Washington and over
400 locations throughout North America. Many classes are live and interactive. The University offers
programs in computer science, business and professional development. Notably, many of the region‟s
most prestigious high-tech public and private organizations are regular subscribers to ITV‟s classes,
including IBM, NASA and the Naval Research Laboratory.




                                                  A-39
                                              APPENDIX 3.3

CURRENT AND PLANNED TWO-WAY DEPLOYMENT BY SPECIFIC CARRIERS

         WorldCom, Sprint, and Nucentrix are the three largest MDS licensees. They currently
operate in 15 markets and cover approximately 80 percent of the MDS licensed areas.6 On July
11, 2000, the three companies entered into a voluntary spectrum management agreement
regarding interference levels, which would allow interference levels among the participants to
exceed those specified in the Two-Way Order. The agreement includes a preferred spectrum
band plan outlining which frequencies operators would use to carry upstream and downstream
traffic based on spectrum availability.7

       WorldCom. During 1999, WorldCom acquired four MDS licensees: CAI Wireless
Systems, Inc., CS Wireless Systems, Inc.,8 Wireless One,9 and PrimeOne Tele-TV.10 As a result,
WorldCom‟s MDS licenses cover 45 million households in 160 markets, from New York City,
NY to Hoggards Mill, GA. WorldCom plans to use these licenses to offer fixed wireless high-
speed Internet access and other broadband services to residential and small office/home office
(“SOHO”) customers, particularly customers that are beyond the reach of wireline DSL.11
WorldCom is currently running trials of MDS high-speed Internet access in five cities: Boston,
MA; Dallas, TX; Baton Rouge, LA; Jackson, MS; and Memphis, TN.12 On August 14, 2000, the
6
   See Coverage Map produced by WorldCom, Appendix B. In March 1996, the MDS spectrum was licensed
pursuant to a geographical licensing system. At that time, the Commission auctioned additional spectrum for the
provision of wireless cable services. The nation was divided into 493 basic trading areas (BTAs) as defined by the
United States Department of Commerce for economic purposes, and these markets were auctioned to the highest
bidders. Although a BTA holder has rights to broadcast throughout its authorized area, within any BTA, incumbent
licensees, whose authorizations predate the 1996 auction, still continue to operate as before the auction. Upon
adoption of the BTA system, the PSAs of incumbent licensees were expanded from a 15-mile radius to a 35-mile
radius.
7
    MMDS Operators Reach Wider Interference Accord for 2-Way Service, COMMUNICATIONS DAILY, July 11, 2000.
8
 WorldCom, Inc., CAI Wireless Information (visited Jan. 27, 2000)
<http://www.wcom.com/about_the_company/investor_relations/mergers+acquisitions/CAI_wireless/>.
9
 Wireless One Completes Reorganization, Becoming MCI WorldCom Subsidiary, PR NEWSWIRE, Dec. 10, 1999.
WorldCom also acquired Wireless One‟s 50 percent interest in Wireless One of North Carolina, LLC, which owned
MDS and WCS licenses in 13 North Carolina markets. Id.
10
     MCIW‟s Wireless Cable Plans Cover Wholesaling, Small Business, COMMUNICATIONS DAILY, July 14, 1999.
11
    Bernie Ebbers, Merger Speech, National Press Club, Jan. 12, 2000, (visited Jan. 21, 2000)
<http://www.worldcom-merger.com/press_room/ebbers_npc_speech.htm>.
12
     In these three markets, Wireless One had previously offered two-way high-speed Internet access on a limited
basis using both MDS and WCS spectrum, and WorldCom is also using both types of spectrum in its trials. Paul
Kagan Associates, Inc., WIRELESS/PRIVATE CABLE INVESTOR, Mar. 9, 2000, at 1. In Jackson, WorldCom is also
testing wireless LAN technology in a 300-unit apartment complex. Paul Kagan Associates, Inc., WIRELESS/PRIVATE
CABLE INVESTOR, Mar. 9, 2000, at 1. MCI WorldCom to Test Fixed Wireless Service in Boston, News Release,
WorldCom, Inc., Mar. 27, 2000; MCI WorldCom Adds Dallas to „Fixed Wireless‟ Service Trials, News Release,
(continued….)


                                                      A-40
company filed its initial applications to offer two-way fixed wireless broadband services in a total
of 70 markets. The company plans to file two-way applications for the remaining 100 markets
during later filing windows.13

        WorldCom is charging its residential trial customers $39.95 per month for two-way
speeds of 310 kbps and businesses $300-$600 per month for speeds of 128 Kbps to 10 Mbps.14
By contrast, the typical cable modem offers speeds of greater than 256 Kbps to 3 Mbps.15 In
addition to its commercial rollout plans, WorldCom announced in April 2000 that it would begin
using MDS to deliver high-speed Internet access to schools, libraries, and community centers in
four rural communities – Raleigh, NC; Houma, LA; Dothan, AL; and Hattiesburg, MS – during
2000.16

        Sprint. Since 1999, Sprint has acquired seven MDS licensees: People‟s Choice TV,
American Telecasting,17 WBS America LLC, Transworld Telecommunications Inc., Videotron
USA,18 Wireless Cable of Florida, Inc., and Nashville Wireless Cable JV.19 Sprint‟s MDS
licenses cover over 30 million households in 83 markets.20
(Continued from previous page)
WorldCom, Inc., Apr. 5, 2000. In Dallas, WorldCom will also be using WCS spectrum in its service trials. Mexico-
U.S. Talks Heat Up on DARS Interference Concerns, AUDIO WEEK, Apr. 24, 2000.
13
     WorldCom Seeks Broadband Fixed Wireless Authority, News Release, WorldCom, Inc., Aug. 14, 2000.
14
     Paul Kagan Associates, Inc., WIRELESS/PRIVATE CABLE INVESTOR, Mar. 9, 2000, at 1.
15
    Although cable offers speeds which can deliver data at speeds up to 100 times faster than telephone modems,
cable was built as a one-way transmission pipe, and must be upgraded to handle two-way capacity. Estimates are
that the cost for the upgrades can run up to $1,000 or more per home. Because of this cost, the buildout is
progressing slowly and the service is not offered in many areas. Another drawback from the user‟s standpoint is that
it is a shared resource. The technology puts a group of nearby users served by the same node into what is essentially
a network, with the bandwidth shared by all users online. As more users go online, there may be a reduction of
throughput in data and consistent speed. Thus, the first user to sign on may find the speeds very fast, but they drop
as soon as the next user signs on.
16
   MCI WorldCom‟s Wireless Internet to Help Bridge the Digital Divide, News Release, WorldCom, Inc., Apr. 26,
2000.
17
     Sprint Closes Acquisition of American Telecasting, Inc., News Release, Sprint Corp., Sept. 23, 1999.
18
   Sprint Completes Purchase of Videotron USA and Operating Units of WBS America, LLC, News Release, Sprint
Corp., Oct. 26, 1999. Videotron USA was the wireless broadband subsidiary of Le Groupe Videotron Ltd., a
Canadian company. Sprint Agrees to Acquire Videotron USA and Transworld Telecommunications Inc., News
Release, Sprint Corp., May 3, 1999.
19
   Sprint Completes Purchase of Videotron USA and Operating Units of WBS America, LLC, News Release, Sprint
Corp., Oct. 26, 1999.
20
   See Implementation of Section 6002(b) of the Omnibus Budget Reconciliation Act of 1993, Annual Report and
Analysis of Competitive Market Conditions with Respect to Commercial Mobile Services, Fifth Report, FCC 00-
289, at E-6 (rel. Aug. 18, 2000).




                                                        A-41
        Sprint is currently offering MDS broadband services in Phoenix, Tucson, Colorado
Springs, Detroit, Houston, Oakland, and San Jose.21 Its service is called Sprint Broadband Direct
and can deliver downstream speeds of 1 Mbps with burst rates of 5 Mbps. In the first phase of
the Detroit rollout, Sprint estimates that about 40 percent of homes and businesses in the
northeast portion of the metropolitan area will have access to the service. Over the next two years
Sprint will extend service to more than 60 percent of homes and businesses in metropolitan
Detroit.22 Notably, Sprint‟s two-way service is currently available to more than 85 percent of the
homes and businesses in Tucson, and Sprint has doubled its Phoenix subscriber base since May
8, 2000.23

         Sprint Broadband Direct costs $49.95 per month for residential customers or $199.95 for
businesses. Customer connections are “instant” and “always-on,” thereby alleviating the need for users
to dial into a modem bank multiple times to establish a connection. The one-time equipment charge
varies with the terms of the service agreement. Customers who choose a two-year plan will receive
equipment for $99. Equipment for a one-year plan costs $199, and month-to-month customers pay $299
for equipment.24

       Sprint has stated that it plans to launch MDS in 10-20 markets by the end of 2000.25 In
August 2000, the company filed applications with the FCC to offer two-way service in 45
markets, and the company plans to file in additional markets in later filing windows.

       Nucentrix. Nucentrix Broadband Networks, Inc. (“Nucentrix,” formerly Heartland
Wireless Systems, Inc.) currently offers two-way high-speed Internet access using MDS spectrum
in Austin and Sherman, TX,26 and is running a trial of the service in Amarillo, TX.27 Nucentrix


21
  Sprint Launches Wireless High Speed Internet Access Service in Houston, News Release, Sprint Corp, Oct. 4,
2000; Sprint to Launch First Broadband Wireless Service for Residential and Small Business Customers in Bay
Area, News Release, Sprint Corp., Oct. 24, 2000.
22
   Sprint Brings High-Speed Wireless Internet Service to Detroit, Business Wire, Sept. 19, 2000; Sprint Rolls Out
Wireless DSL in Phoenix, COMMUNICATIONS DAILY, May 9, 2000; Sprint Launches Second Broadband Market;
Tucson Gains Independence from Slow Internet Connections, News Release, Sprint Corp., June 29, 2000.
23
   Collins, Jonathan, WorldCom, Sprint Rethink their Wireless Last-Mile Plans, tele.com (July 31, 2000) (“We
[Sprint] have not had to spend a single cent of advertising or marketing money . . . We‟re actually afraid to spend
money on advertising because we‟ve already experienced a flood . . .of business.”).
24
  Sprint to Launch First Broadband Wireless Service for Residential and Small Business Customers in Bay Area,
News Release, Sprint Corp., Oct. 24, 2000.
25
     Nancy Gohring, All Chips on MMDS, TELEPHONY, Dec. 20, 1999.
26
     Nucentrix Broadband Networks, Executive Summary.
27
  Nucentrix Broadband Networks Reports Financial Results for its Quarter Ended September 30, 2000, News
Release, Nucentrix Broadband Networks, Inc., Oct. 30, 2000.




                                                      A-42
plans to launch the service in 15-20 markets by the end of 2001.28 The company filed
applications to offer two-way service in 70 markets during the July-August 2000 two-way filing
window. Nucentrix holds licenses that cover approximately 9.4 million homes in 95 small and
medium markets in Texas and the Midwest.29

      Other Operators. In addition to the three companies discussed above, several small
companies have also begun using MDS to offer high-speed Internet access. See table attached as
Appendix C for a complete list of their plans and current offerings.

         In Mobile, AL, Advanced Wireless Systems, Inc. (“AWS”) offers one-way high-speed Internet
access. In August 2000, AWS completed its purchase of Digital Wireless Systems, Inc. (“DWS”). DWS
had been offering high-speed Internet access using MDS and leased ITFS spectrum in four cities – Baton
Rouge, LA; Shreveport, LA; Reading, PA; and Clarksville, TN – and AWS has continued operations in
these markets. AWS states that it primarily serves rural and outlying areas where the delivery of
traditional land-based cable television service is impractical.30 However, AWS is focusing primarily on
businesses and, to a lesser extent, individuals as potential customers for its high-speed Internet access
service.

       LMA Systems, Inc. (“LMA”) is offering high-speed Internet access in three mid-Atlantic
markets: Sunbury, PA; Wilkes-Barre, PA; and Lynchburg, VA. LMA offers two-way access at 1.54
Mbps downstream and 768 kbps upstream, and is currently focusing on business customers.

        World Wide Wireless Communications, Inc. (“WWWC”) currently offers high-speed
Internet access in Concord, CA and in several cities outside the United States. WWWC plans to
launch service in several additional U.S. cities: San Marcos, Ukiah, and San Diego, CA; South
Bend, IN; Hot Springs, AR; Hilo, HI; Grand Rapids, MI; Aspen and Vail, CO; Key West, FL;
Casper, WY; La Grange, OR; and Pierre, SD.31

         Sioux Valley Wireless (“SVW”), a subsidiary of Sioux Valley Southwestern Electric, has
launched a two-way MDS Internet access service covering communities within a 30-mile radius
of its transmission facilities at Sioux Falls and Colman, South Dakota.32 SVW offers several

28
     Nucentrix Broadband Networks, Executive Summary.
29
   Fred Dawson, Broadband Wireless Gets to the (Multi)Point, INTERACTIVE WEEK FROM ZDWIRE, Mar. 13, 2000,
available in 2000 WL 4065337.
29
  Nucentrix Broadband Networks Announces Effectiveness of Shelf, BUSINESS WIRE, Dec. 17, 1999. Nucentrix
Broadband Networks, Executive Summary.
30
     Advanced Wireless Systems, Inc., Form 10QSB, Aug. 25, 2000.
31
   World Wide Wireless Communications, Inc., Form SB-2/A, Jun. 30, 2000; World Wide Wireless
Communications, Inc., Form 10QSB, Aug. 21, 2000.
32
    See <http://www.svswe.com>. SWV also provides traditional wireless cable service to nearly 6,000 subscribers
in South Dakota, Iowa, Nebraska and Minnesota from its existing transmission facilities.




                                                     A-43
classes of wireless Internet service, from single home computer installations to large networked
systems. The company‟s basic wireless Internet service operates at 128 kbps. Recently, SVW‟s
wireless system was used to enable Internet users to watch a “streaming video” version of the
Bob Burns Dakota Bowl between two Sioux Valley high schools. This was the first time that a
South Dakota high school football game was transmitted live over the Internet.

       Wireless First, Inc. (“Wireless First”) currently offers high-speed Internet access, called
SpeedConnect, using MDS spectrum in Traverse City, MI and its surrounding five counties on
the Upper Peninsula of Michigan (Grand Traverse, Leelanau, Benzie, Kalkaska, Antrim).
Wireless First offers one- and two-way service to residential and business customers at a
maximum speed of 256 kbps. Its MDS licenses (either leased or owned) currently cover 11
additional counties, and Wireless First plans to roll out service to those counties in the future.
Wireless First plans to expand geographic reach of the service to Clare, Gartiot, Isabella,
Manistee, Missaukee, Osceloa, Wexford, Otsego, Emmet, Cheboygan and Charlevoix counties.33

       Cache Valley AIRNET (“CVAIRNET”) currently offers two-way Internet access over
MDS frequencies in the Cache Valley region of Northern Utah and Southeastern Idaho, including
the communities of Logan, Smithfield, Hyrum, Preston, Wellsville, Richmond, Paradise and
surrounding areas.34 From its transmission facilities on Little Mountain near Newton, Utah,
CVAIRNET‟s service is up to 347 times faster than 28.8 kbps modem, up to 78 times faster than
ISDN, and up to 8 times faster than traditional T1 service. CVAIRNET offers service to both
residential and business customers, providing the same rate speed connectivity to both.

       Alaska Wireless Cable (“AWC”) has launched a two-way MDS Internet service,
marketed as netSpeed, covering most of Fairbanks and a large portion of the North Pole,
Ft.Wainwright, Eielson Air Force Base, and other Fairbanks North Start Borough areas.35
AWC‟s service is available to both residential and business users at speeds up to 256 kbps and
512 kbps downstream.

        Virginia Communications ESpeed (“VCE”) has launched two-way MDS Internet service
in and around Prescott, Arizona, using the E-group channels downstream and channel MDS1
upstream. VCE‟s service area encompasses approximately one-third of a large rural area around
Prescott that has no cable or DSL service and, in some cases, no landline telephone service. In
the Commission‟s recent initial filing window for two-way MDS/ITFS applications, VCE filed
for authority to construct three additional hubs and to use additional MDS frequencies. Those
applications, once granted, will enable VCE to expand the reach of its service to additional rural
areas that are similarly underserved. VCE also intends to file applications in the Commission‟s
next two-way filing window to launch service in Davenport, Cedar Rapids, Waterloo, and Iowa

33
   See <http://www.speedconnect.com>; Regional Wireless Operators Select Hybrid Networks‟ 2-Way Today
Solution To Launch Multiple Markets, PR NEWSWIRE, Jan. 10, 2000.
34
     See <http://www.cvairnet.com>.
35
     See <http://www.awcable.com>.




                                                A-44
City, Iowa; Huntington, West Virginia; Portsmouth, Chillicothe, Zanesville and Athens, Ohio;
and Erie, Pennsylvania.

       Oxford Telecom recently launched two-way MDS Internet service in Portland, Maine,
including Internet access, Virtual Private Networks, data vaulting and e-commerce applications.36
 Similarly, Third-Rail Wireless Services has launched two-way MDS Internet service in Nashua,
New Hampshire, offering Internet access, video conferencing, IP Telephony, and WAN-WAN
connectivity.37

        W.A.T.C.H. TV Company (“WTC”), provides both multichannel video programming and
Internet access in the Lima, OH. The company began providing one-way Internet access over a
year ago and recently began using its MDS channels 1 and 2 for upstream transmissions. WTC
has invested over $6.5 million dollars to digitize its channels and convert its subscribers to digital
technology – a step necessary to free up spectrum for the two-way wireless Internet offering.

        Over the past six months, WinBeam, Inc. (“WinBeam”), has been acquiring MDS and
ITFS spectrum in southern New York State, western Pennsylvania, western Maryland, West
Virginia and western Virginia in order to provide a regional Internet access service. WinBeam
plans to submit numerous two-way applications when the rolling, one-day filing window begins
and to begin construction soon after the applications are granted.

        nTelos (formerly CFW Communications, Inc.) operates wireless cable systems in
Charlottesville and the Shenandoah Valley of Virginia and controls MDS/ITFS channels in
Richmond and Lynchburg, VA. The company and its affiliates submitted close to twenty
applications for two-way authorizations during the August filing window. nTelos plans to
aggressively roll-out Internet access service (and is looking at IP telephony) as its applications
are granted and equipment becomes available.

        Teton Wireless (“Teton”) operates analog wireless cable systems in Idaho Falls and Twin
Falls, ID and Missoula, MT, and has smaller channel positions elsewhere in the Northwest.
Teton is also in the process of acquiring a wireless cable system in Pocatello, ID. Teton
submitted applications during the initial filing window to deploy two-way Internet access in 4
markets using MDS channels 1 and 2A. Teton is now exploring the various possible migration
paths for converting its existing video services to digital technology in order to free spectrum in
the 2.5 GHz band for Internet access. The company plans to begin offering service in late 2001.




36
     See <http://www.spikebroadband.net/press/pr/oxford_122099.html>.
37
     See <http://www.third-rail.net>.




                                                     A-45
                                                                                               APPENDIX 3.4


                                                                    Generic Band Plans for 2500-2690 MHz (Planned Use)


     Channels       1       2            A1 B1 A2 B2 A3 B3 A4 B4 C1 D1 C2 D2 C3 D3 C4 D4 E1 F1 E2 F2 E3 F3 E4 F4 G1 H1 G2 H2 G3 H3 G4 I




                                                                                                                                                                                      G2
                                                                                                                                                                            G1




                                                                                                                                                                                                G3


                                                                                                                                                                                                          G4
                                                                                               C2
                                                                                                     D2
                                                                                                           C3
                                                                                                                D3
                                                                                                                     C4
                                                                                                                          D4




                                                                                                                                                                                 H1
                                                                         A4


                                                                                     C1
                                                                                          D1




                                                                                                                               E1




                                                                                                                                                                                           H2


                                                                                                                                                                                                     H3
                                         A1
                                                B1
                                                     A2
                                                          B2
                                                               A3
                                                                    B3


                                                                               B4




                                                                                                                                            E2


                                                                                                                                                      E3


                                                                                                                                                                 E4
                                                                                                                                                            F3


                                                                                                                                                                       F4
                                                                                                                                      F1


                                                                                                                                                 F2
MDS/ITFS
                  1
                         2




                                                                                                                                                                                                           I
Channels
                  MDS                                               ITFS Channels                                                          MDS Channels                           Interleaved                R




                                                                                                                                                                                      G2
                                                                                               C2
                                                                                                     D2
                                                                                                           C3
                                                                                                                D3
                                                                                                                     C4
                                                                                                                          D4




                                                                                                                                                                            G1
                                                                                                                                                                                 H1




                                                                                                                                                                                                G3


                                                                                                                                                                                                          G4
                                                                         A4


                                                                                     C1
                                                                                          D1




                                                                                                                               E1




                                                                                                                                                                                           H2


                                                                                                                                                                                                     H3
                                         A1
                                                B1
                                                     A2
                                                          B2
                                                               A3
                                                                    B3


                                                                               B4




                                                                                                                                            E2


                                                                                                                                                      E3


                                                                                                                                                                 E4
                                                                                                                                                            F3


                                                                                                                                                                       F4
                                                                                                                                      F1


                                                                                                                                                 F2
                  1
                         2




                                                                                                                                                                                                           I
WorldCom-1
                    Up                                     Video                                     Upstream                              Separation             Downstream                         Other




                                                                                                                                                                                      G2
                                                                                                                                                                            G1




                                                                                                                                                                                                G3


                                                                                                                                                                                                          G4
                                                                                               C2
                                                                                                     D2
                                                                                                           C3
                                                                                                                D3
                                                                                                                     C4
                                                                                                                          D4




                                                                                                                                                                                 H1
                                                                         A4


                                                                                     C1
                                                                                          D1




                                                                                                                               E1




                                                                                                                                                                                           H2


                                                                                                                                                                                                     H3
                                         A1
                                                B1
                                                     A2
                                                          B2
                                                               A3
                                                                    B3


                                                                               B4




                                                                                                                                            E2


                                                                                                                                                      E3


                                                                                                                                                                 E4
                                                                                                                                                            F3


                                                                                                                                                                       F4
                                                                                                                                      F1


                                                                                                                                                 F2
                  1
                         2




                                                                                                                                                                                                           I
WorldCom-2
                    Up                      Supercell Up                  Mini Up G                       Separation           G       Supercell Dn                   G          Minicell Dn              Ot




                                                                                                                                                                                      G2
                                                                                               C2
                                                                                                     D2
                                                                                                           C3
                                                                                                                D3
                                                                                                                     C4
                                                                                                                          D4




                                                                                                                                                                                 H1
                                                                                                                                                                            G1




                                                                                                                                                                                                G3


                                                                                                                                                                                                          G4
                                                                                     C1
                                                                                          D1




                                                                                                                                                                                           H2


                                                                                                                                                                                                     H3
                                                                         A4




                                                                                                                               E1
                                         A1
                                                B1
                                                     A2
                                                          B2
                                                               A3
                                                                    B3


                                                                               B4




                                                                                                                                            E2


                                                                                                                                                      E3


                                                                                                                                                                 E4
                                                                                                                                                            F3


                                                                                                                                                                       F4
                                                                                                                                      F1


                                                                                                                                                 F2
                  1
                         2




                                                                                                                                                                                                           I
WorldCom-3
                    Up                                    Upstream                                  Separation                        Downstream                            G              Other




                                                                                                                                                                                      G2
                                                                                               C2
                                                                                                     D2
                                                                                                           C3
                                                                                                                D3
                                                                                                                     C4
                                                                                                                          D4




                                                                                                                                                                                 H1
                                                                                                                                                                            G1




                                                                                                                                                                                                G3


                                                                                                                                                                                                          G4
                                                                         A4


                                                                                     C1
                                                                                          D1




                                                                                                                               E1




                                                                                                                                                                                           H2


                                                                                                                                                                                                     H3
                                         A1
                                                B1
                                                     A2
                                                          B2
                                                               A3
                                                                    B3


                                                                               B4




                                                                                                                                            E2


                                                                                                                                                      E3


                                                                                                                                                                 E4
                                                                                                                                                            F3


                                                                                                                                                                       F4
                                                                                                                                      F1


                                                                                                                                                 F2
                  1
                         2




                                                                                                                                                                                                           I
 Sprint-1
                    Up                                                          Downstream                                                                 Separation                  Upstream




                                                                                                                                                                                      G2
                                                                                               C2
                                                                                                     D2
                                                                                                           C3
                                                                                                                D3
                                                                                                                     C4
                                                                                                                          D4




                                                                                                                                                                            G1
                                                                                                                                                                                 H1




                                                                                                                                                                                                G3


                                                                                                                                                                                                          G4
                                                                         A4


                                                                                     C1
                                                                                          D1




                                                                                                                               E1




                                                                                                                                                                                           H2


                                                                                                                                                                                                     H3
                                         A1
                                                B1
                                                     A2
                                                          B2
                                                               A3
                                                                    B3


                                                                               B4




                                                                                                                                            E2


                                                                                                                                                      E3


                                                                                                                                                                 E4
                                                                                                                                                            F3


                                                                                                                                                                       F4
                                                                                                                                      F1


                                                                                                                                                 F2
                  1
                         2




                                                                                                                                                                                                           I
 Sprint-2
                    Up                           Upstream                           Separation                                                    Downstream




                                                                                                                                                                                      G2
                                                                                               C2
                                                                                                     D2
                                                                                                           C3
                                                                                                                D3
                                                                                                                     C4
                                                                                                                          D4




                                                                                                                                                                                 H1
                                                                                                                                                                            G1




                                                                                                                                                                                                G3


                                                                                                                                                                                                          G4
                                                                         A4


                                                                                     C1
                                                                                          D1




                                                                                                                               E1




                                                                                                                                                                                           H2


                                                                                                                                                                                                     H3
                                         A1
                                                B1
                                                     A2
                                                          B2
                                                               A3
                                                                    B3


                                                                               B4




                                                                                                                                            E2


                                                                                                                                                      E3


                                                                                                                                                                 E4
                                                                                                                                                            F3


                                                                                                                                                                       F4
                                                                                                                                      F1


                                                                                                                                                 F2
                  1
                         2




                                                                                                                                                                                                           I
Nucentrix-1
                    Up                                                                Downstream                                                                      Separation      G2    Upstream
                                                                                               C2
                                                                                                     D2
                                                                                                           C3
                                                                                                                D3
                                                                                                                     C4
                                                                                                                          D4




                                                                                                                                                                                 H1
                                                                                                                                                                            G1




                                                                                                                                                                                                G3


                                                                                                                                                                                                          G4
                                                                         A4


                                                                                     C1
                                                                                          D1




                                                                                                                               E1




                                                                                                                                                                                           H2


                                                                                                                                                                                                     H3
                                         A1
                                                B1
                                                     A2
                                                          B2
                                                               A3
                                                                    B3


                                                                               B4




                                                                                                                                            E2


                                                                                                                                                      E3


                                                                                                                                                                 E4
                                                                                                                                                            F3


                                                                                                                                                                       F4
                                                                                                                                      F1


                                                                                                                                                 F2
                  1
                         2




                                                                                                                                                                                                           I
Nucentrix-2
                    Up                          Upstream                      Separation                                                         Downstream
                         2160/2
            MHz
                  2150




                                                                                                                               2596




                                                                                                                                                                                                          2686
                                         2500




                                                                                          54
                                                                                               60




                                                                                                                                                 14
                                                                                                                                                      20
                                                                                                                                                           26




                                                                                                                                                                                                     74
                                                                                                                                                                                                          80
                                                     12
                                                          18
                                                               24
                                                                    30
                                                                         36
                                                                              42
                                                                                    48



                                                                                                    66
                                                                                                          72
                                                                                                                78
                                                                                                                     84
                                                                                                                          90




                                                                                                                                                                 32
                                                                                                                                                                      38
                                                                                                                                                                            44
                                                                                                                                                                                 50
                                                                                                                                                                                      56
                                                                                                                                                                                           62
                                                                                                                                                                                                68
                                                6




                                                                                                                                      2
                                                                                                                                           8




                                  BLUE                    Separation-Video
                             YELLOW                       Digital-Video, Voice, Data
                                  GRAY                    Other-Guardband, Broadcast, Data Simulcast




                                                                                                                A-46
                                           APPENDIX 3.5


TECHNICAL CHARACTERISTICS OF MDS/ITFS STATIONS

        The technical characteristics of the MDS and ITFS stations can be summarized as follows.
Tables 3-A and 3-B list the characteristics of stations used for traditional „one-way‟ point-to-multipoint
ITFS and MDS (also called MMDS) systems. These systems are used primarily for the distribution to
educational institutions (ITFS systems) of instructional video programming and for the distribution to
paying customers (MDS systems) of entertainment video programming.


Table 3-A Stations                   Table 3-B Stations                      Signal

Main Station Transmitter >>>>>>> Customer Receivers                  Downstream NTSC
                                                                     (6 MHz channels)

Main Station Receiver <<<<<<<<< Customer Narrowband                  Upstream Audio
                                Response Transmitters                (125 kHz channels)



        Tables 3-C and 3-D list the characteristics of stations used for two-way „cellularized‟ digital
MDS and ITFS systems. These systems are used primarily for wireless internet access and other two-
way wireless communications between fixed points by educational institutions (ITFS systems) and by
paying customers (MDS systems).



Table 3-C Stations                    Table 3-D Stations                     Signal

Main/Booster Station >>>>>>>>>> Customer Response                    Downstream Digital
Transmitter                     Station Receivers                    1-30 Mbps typical

Hub Station Receiver <<<<<<<<<< Customer Response                    Upstream Digital
                                Station Transmitters                 250K-1 Mbps typical




                                                  A-47
                                           TABLE 3-A
           ITFS/MDS Point-to-Multipoint One-Way System Base Station Characteristics
                         (Main Station Transmitter; Main Station Receiver)
                 Parameter                                  Specification                                              Notes
Main Station Transmitter
   Spectrum Available                         2150-2162 & 2500-2686 MHz
   Signal Bandwidth                           6 MHz nominal                                                            1
   Power Output                               Not specified                                                            2
   Antenna Gain                               Not specified                                                            3
   Antenna Beam Tilt                          Permitted                                                                4
   EIRP                                        2000 Watts (33 dBW)                                                    5
   Modulation Type                            NTSC Composite Video/Audio                                               7
   Emission Bandwidth                         @ -38 dB        6 MHz
                                              @ -60 dB        7.5 MHz

Path Length                                                   Up to 35 Miles
Free Space Path Loss                                          135.5 dB @ 35 Miles

Main Station Receiver
   Signal Spectrum                                            2686-2690 MHz                                            8
   Signal Bandwidth                                           125 kHz nominal
   Emission Bandwidth                                         @ -35 dB      125 kHz
                                                              @ -60 dB      375 kHz
     Modulation Type                                          AM or FM                                                 9
     Antenna Gain                                             Not specified                                            10
     Signal Level (from individually-licensed                 Various                                                  11
     narrowband Response Stations)
     Noise Figure                                             5 Db
     Noise Level                                              -107 dBm  N  -127 dBm (typical)
     SNR                                                      60  SNR  40 dB (typical)
     Interference Protection                                  None
Notes
1. Licensees are authorized one or more 6 MHz channels per station.
2. The rules do not restrict transmitter output, however the peak aural power must not exceed 10% of the peak visual power
     for standard NTSC composite video/audio signals.
3. The rules do not specify maximum or minimum permissible antenna gain. Licensees may use omnidirectional antennas
     and/or directional antennas as needed to achieve desired area coverage.
4. The rules do not restrict beam tilt, either mechanical or electrical, although the details of the tilted beam pattern must be
     specified on the station application form.
5. The maximum permissible EIRP per 6 MHz channel is 2000 watts (33 dBW) for MDS/ITFS Main stations in one-way
     systems utilizing an omnidirectional antenna (i.e. no azimuthal-plane directivity). For stations using directional (i.e.
     azimuthal-plane directivity) and sectorized antenna systems, the maximum EIRP per 6 MHz channel is given by the
     formula 33 dBW + 10 log (360/beamwidth), with an upper limit of 39 dBW permissible. See Rule Sections 21.904
     (MDS) and 74.935 (ITFS).
6. Digital modulation for the transmission of one or more visual and composite aural signals, and/or for the transmission of
     data, is also permitted pursuant to the provisions of the Commissions Digital Declaratory Ruling, 11 FCC Rcd at 18840.
7. See Rule Sections 21.905 (MDS) and 74.936 (ITFS).
8. The 2686-2690 MHz spectrum available for individually-licensed Response Stations transmitting to Main Station receivers
     in one-way systems is subdivided into 31 channels of 125 kHz bandwidth each, with the center of the 1st channel at



                                                              A-48
    2686.0625 MHz and the center of the 31st channel at 2689.8125 MHz. All 31 channels are available to ITFS licensees
    and 4 channels are available to MDS licensees on a shared basis with ITFS licensees. See Rule Sections 21.901(b)
    (MDS) and 74.939 (ITFS).
9. Digital emissions are also permissible pursuant to the to the provisions of the Commission‟s Digital Declaratory Ruling, 11
     FCC Rcd at 18840.
         10. The Main Station receiving antennas in a one-way system are used for reception of signals transmitted by
         individually-licensed narrowband (125 kHz) Response Stations. Directional and/or omnidirectional Main Station
         receiving antennas, or a combination of both, are permissible.
11.This is dependant on path lengths from the individually-licensed narrowband response station transmitters to the Main
    Station, as well as the power level and the antennas in use.




                                                             A-49
                                        TABLE 3-B
           ITFS/MDS Customer Receive Stations and Individually-Licensed Customer
                Narrowband Response Station Transmitters in One-Way Systems
           (Customer Receiver; Customer Narrowband Response Transmitter, if used)
                Parameter                                Specification                                              Notes
Narrowband Response Station Transmitter
   Spectrum Available                      2686-2690 MHz                                                           1
   Signal Bandwidth                        125 kHz                                                                 1
   Power Output                            2 Watts (3 dBW) Maximum                                                 2
   Antenna Gain                            Gain Antenna Required                                                   3
   Transmitted EIRP                         40 Watts (16 dBW) Maximum                                             4
   Modulation Types                        AM, FM                                                                  5
Emission Bandwidth                         @ 35dB          125 kHz                                                 6
                                           @ 60 dB         375 kHz

Path Length                                                  Up to 35 Miles
Free Space Path Loss                                         135.5 dB @ 35 Miles

Customer Receiver
   Signal Spectrum                                           2150-2162 & 2500-2686 MHz
   Signal Bandwidth                                          6 MHz nominal
   Emission Bandwidth                                        @ -38 dB        6 MHz
                                                             @ -60 dB        7.5 MHz
    Modulation Type (Rx)                                     NTSC Composite Video/Audio                            7
    Antenna Gain                                             Directional Antenna Required                          8
    Received Signal Level                                    -52.5 dBm                                             9
    Noise Figure                                             5 dB
    Noise Level                                              -100.2 dBm                                            10
    SNR                                                      47.7 dB                                               11
    Interference Protection                                  Service Area Protection; Registered                   12
                                                             Receive Site Protection
Notes
1. See Rule Sections 21.901(b)(5) (MDS) and 74.949 (ITFS).
2. See Rule Sections 21.909(g)(2) (MDS) and 74.949(c)(2) (ITFS).
3. See Rule Section 21.949(e) (MDS) and 74.937(b) (ITFS).
4. See Rule Sections 21.904(a) (MDS) and 74.949(c)(3) (ITFS).
5. See Rule Sections 21.905 (MDS) and 74.936 (ITFS). Digital emissions are also permitted pursuant to the provisions of the
     Commission‟s Digital Declaratory Ruling, 11 FCC Rcd at 18840.
6. See 21.909(j) (MDS) and 74.949(k) (ITFS).
7. The modulation type received at the customer receiver (from the Main Station transmitter in a one-way system) may also be
     digital, pursuant to the provisions of the Commission‟s Digital Declaratory Ruling, 11 FCC Rcd at 18840.
8. See Rule Sections 21.906(d) (MDS) and 74.937(a) (ITFS).
9. + 63 dBm (Main/Booster Transmitter EIRP) – 135.5 dB (35 mi. PL) + 20 dBi (gain of assumed Rx antenna) = -52.5 dBm.
10. For thermal noise only, excluding interference; -106.2 dBm (kTB for 6 MHz) + 5 dB (NF) + 1 dB (cable loss) = -100.2
     dBm.
11. –52.5 + 100.2 = 47.7.
12. Protection for Customer Receivers in most MDS one-way systems licensed in 1997 and later is primarily in the form of
     protection of the service area in which they are located. Specifically, at the service area boundary, all geograpically



                                                             A-50
adjacent licensees must engineer their systems to limit the calculated free space power flux density at any shared border
with the protected system to a maximum value of –73 dBW/m2 (per 6 MHz bandwidth) as measured with an FCC
reference antenna at a height of 10 meters. For pre-1997 MDS one-way systems and for all ITFS one-way systems,
additional requirements for protection inside the service area are imposed in the form of permissible D/U ratios of 45 dB
for cochannel interference and 0 dB for adjacent channel interference. See Rule Sections 21.902 (MDS), 21.909 (MDS),
21.913 (MDS), 74.903 (ITFS), 74.939 (ITFS) and 74.985 (ITFS).




                                                        A-51
                                           TABLE 3-C
               MDS/ITFS Point-to-Multipoint 2-Way System Base Station Characteristics
                   (Main/High Power Booster Transmitter; Hub Station Receiver)
                  Parameter                               Specification                                                Notes

Main/Booster Station Transmitter
   Spectrum Available                                         2150-2162 & 2500-2690 MHz
   Signal Bandwidth                                           6 MHz nominal                                           1
   Power Output                                               Not specified                                           2
   Antenna Gain                                               Not specified                                           3
   Antenna Beam Tilt                                          Permitted                                               4
   EIRP                                                        2000 Watts (33 dBW)                                   5
   Access Techniques                                          TDMA/CDMA                                               6
   Modulation Types                                           QAM, VSB, COFDM                                         7
   Emission Bandwidth                                         @ -25 dB       6 MHz                                    8
                                                              @ -40 dB       6.5 MHz
                                                              @ -60 dB       12 MHz

Path Length (Main/Booster Station to Response Up to 35 Miles                                                          9
Station Receiver)
Free Space Path Loss                          135.5 dB @ 35 Miles

Hub Station Receiver
   Signal Spectrum                                            2500-2690 MHz                                           10
   Signal Bandwidth                                           6 MHz nominal                                           11
   Emission Bandwidth                                         @ -25 dB       6 MHz
                                                              @ -40 dB       6.5 MHz
                                                              @ -60 dB       12 MHz
     Modulation Types                                         QAM, VSB, COFDM                                         7
     Antenna Gain                                             10 dBi typical                                          12
     Signal Level (at Hub Station receiver from               -62.5 dBm                                               13
     Response Station transmitter)
     Noise Figure                                             2.5 dB
     Noise Level                                              -102.7 dBm                                              14
     SNR                                                      40.2 dB                                                 15
     Interference Protection                                   1 dB Rx Noise Floor Degradation                       16
Notes
1. A licensee may be authorized one or more 6 MHz channels per station and may subdivide a 6 MHz channel into multiple
     smaller channels (subchannelization) and may itself, or in combination with one or more other licensees, aggregatge
     multiple contiguous 6 MHz channels into larger channels (superchannelization). See Rule Sections 21.905 (MDS) and
     74.936 (ITFS).
2. The rules do not restrict Main/Booster transmitter power output.
3. The rules do not specify maximum or minimum permissible antenna gain. Licensees may use omnidirectional antennas
    and/or directional antennas as needed to achieve desired area coverage. Main and Booster Stations utilize multiple
    directional antennas to achieve sectorized coverage of the service area as a means of achieving frequency reuse. See Rule
    Sections 21.906(a) (MDS), 74.931(b)(3) (ITFS) and 74.937(b) (ITFS).
4. The rules do not restrict beam tilt, either mechanical or electrical, although the details of the tilted beam pattern must be
     specified on the station application form.
5. The maximum permissible EIRP per 6 MHz channel is 2000 watts (33 dBW) for stations utilizing an omnidirectional




                                                              A-52
     antenna (i.e. no azimuthal-plane directivity). For stations using directional (i.e. azimuthal-plane directivity) and
     sectorized antenna systems, the maximum EIRP per 6 MHz channel is given by the formula 33 dBW + 10 log
     (360/beamwidth), with an upper limit of 39 dBW permissible. Rule Sections 21.904 (MDS) and 74.935 (ITFS).
6. See Rule Sections 21.905 (MDS) and 74.936 (ITFS).
7. In addition, other forms of digital modulation are permitted if the applicant provides a showing that interference will not
     result from their use. See Rule Sections 21.905 (MDS) and 74.936 (ITFS).
                          8. Emission measurements are to be made in accordance with the formulas set out at Rule Section
                          21.908 (MDS and ITFS). Attenuations apply only at edges of 6 MHz channels, not to subchannels
                          within a 6 MHz channel. For superchannels, attenuations apply only at the upper and lower edges of
                          the superchannel, not to channels within the superchannel.
9. Path length from Main/Booster transmitter to Response Station receiver will depend on size of service area to be covered
     and the amount of „cellularization‟ used, i.e. if a service area is served by multiple cells, the path lengths in each cell will
     be significantly shorter than if a single cell is used to cover the entire 35 mile radius of a typical service area.
10. The 6 MHz channels listed in Note 1, above, for point-to-multipoint use in the MDS and ITFS Services may also be used
     at Response (customer) stations for transmissions which are received by the Base Station receiver (“Hub Station”). MDS
     and ITFS licensees are permitted to allocate the channels assigned to their systems on a real-time basis for both
     downstream (point-to-multipoint) and upstream (multipoint-to-point) use without regard to which channels are used for
     which purpose so long as all interference protection criteria are met with respect to neighboring systems. Upstream and
     downstream bandwidths may be symmetrical or asymmetrical, with some or most systems utilizing greater bandwidth
     downstream than upstream. Downstream bit rates in a range of 1-30 Mbps are likely, with upstream bit rates likely in a
     range of 250 kbps- 1 Mbps.
11. The bandwidths of the signals transmitted from 2-Way System Response Stations which are received at the base station
     receiver (“Hub Station”) are determined by the licensee of the system on a real-time basis. (See Note 2, above.) The
     bandwidth may be 6 MHz, or a fraction thereof, or a multiple thereof.
12. Gain of a parabolic antenna with a half-power beamwidth of approximately 30 degrees. Twelve such sector antennas
    would be necessary to provide omnidirectional coverage at the Hub receiving Station.
13. + 63 dBm (EIRP) – 135.5 dB (35 mi. PL) + 10 dBi (Rx Ant Gain) = -62.5 dBm
                       14. For thermal noise only, excluding interference; –106.2 dBm (kTB for 6 MHz) + 2.5 dB (NF) + 1
                       dB (Cable Losses) = -102.7 dBm
15. –62.5 + 102.7 = 40.2
16. See Rule Sections 21.909(i) (MDS) and 74.939(i) (ITFS). See also Appendix D to the Report and Order in MM Docket
     97-217, 13 FCC Rcd 19,112 (1998), at paragraphs 40-49.




                                                                A-53
                                            TABLE 3-D
                   MDS/ITFS Response (Customer) Stations in 2-Way Systems
                             (Response Station Transmitter & Receiver)
                 Parameter                                    Specification                                              Notes
Response Station Transmitter
   Spectrum Available                           2150-2162 & 2500-2690 MHz
   Signal Bandwidth                             6 MHz nominal                                                           1
   Power Output                                 2 Watts (3 dBW)                                                         2
   Antenna Gain                                 0                                                                      3
   EIRP                                          2000 Watts (33 dBW)                                                   4
   Access Techniques                            TDMA/CDMA                                                               5
   Modulation Types                             QAM, VSB, COFDM                                                         6
   Emission Bandwidth                           @ -25 dB       6 MHz                                                    7
                                                @ -40 dB       6.25 MHz
                                                @ -60 dB       12 MHz

Path Length (Response Station Transmitter to Up to 35 Miles
Hub Station Receiver)
Free Space Path Loss                         135.5 dB @ 35 Miles

Response Station Receiver (from Main/Booster
Station)
    Signal Spectrum                                            2500-2690 MHz                                            9
    Signal Bandwidth                                           6 MHz nominal                                            10
    Emission Bandwidth                                         @ -25 dB        6 MHz                                    7
                                                               @ -40 dB        6.25 MHz
                                                               @ -60 dB        12 MHz
     Modulation Types                                          QAM, VSB, COFDM                                          6
     Antenna Gain                                              Directional Antenna Required                             11
     Signal Level                                              -52.5 dBm                                                12
     Noise Figure                                              5 dB
     Noise Level                                               -100.2 dBm                                               13
     SNR                                                       47.7 dB                                                  14
     Interference Protection                                   System Service Area Protected                            15
Notes
1. Response Station transmitters in 2-Way systems are not individually licensed. MDS/ITFS 2-Way system licensees are
    authorized one or more 6 MHz channels per system and may allocate the licensed bandwidth between and among Main,
    Booster and Response Station transmitters as needed on a real-time basis. A licensee may subdivide a 6 MHz channel
    into multiple smaller channels (subchannelization) and may, itself, or incombination with one or more other licensees,
    aggregate multiple contiguous 6 MHz channels into larger channels (superchannelization). See Rule Sections 21.905
    (MDS) and 74.936 (ITFS).
2. See Rule Sections 21.909(g)(2) (MDS) and 74.939(g)(2) (ITFS)
3. See Rule Sections 21.909(g)(4) (MDS) and 74.939(g)(4) (ITFS)
4. See Rule Sections 21.909(g)(3) (MDS) and 74.939(g)(3) (ITFS)
5.See Rule Sections 21.905 (MDS) and 74.936 (ITFS)
6. In addition, other forms of digital modulation will be permitted if the applicant provides a showing that interference will not
      result from their use. See Rule Sections 21.905 (MDS) and 74.936 (ITFS).
7.Emission measurements are to be made in accordance with the formulas set out at Rule Section 21.908 (MDS and ITFS).
    Attenuations apply only at the edges of 6 MHz channels, not to subchannels within a 6 MHz channel. For superchannels,



                                                               A-54
     attenuations apply only at upper and lower edges of the superchannel, not to channels within the superchannel.
8. Path length from response station transmitter to Base Station receiver (Hub Station) will depend on size of service area to
     be covered and the amount of „cellularization‟ used, i.e. if a service area is served by multiple cells, the path lengths in
     each cell will be significantly shorter than if a single cell is used to cover the entire 35 mile radius of a typical service
     area.
9. The 6 MHz channels listed in Note 1, above, for „upstream‟ use for 2-Way systems in the MDS and ITFS Services are
     identical to those available for „downstream‟ (Main/Booster transmitters to Response Station receivers) use in these
     services and such channels may be subchannelized and superchannelized to form channels or less or greater width,
     respectively.
10. The signal received by the Response Station receiver (transmitted from an MDS or ITFS Main or Booster Station) may be
     6 MHz in bandwidth, or less than 6 MHz (if the 6 MHz channel has been divided into subchannels) or greater than 6
     MHz (if 2 or more 6 MHz channels have been combined to form a superchannel). This bandwidth may vary
     dynamically, on a real-time basis, as needed by the system operator to adapt to system information transmission
     requirements.
11. There are no requirements for receiver antenna directivity; however, for interference calculations, it is assumed that the
     receiver antenna has, at a minimum, a directive pattern meeting the requirements of the FCC reference receiving antenna.
      See Rule Sections 21.906(d) (MDS), 21.909(g)(4) (MDS) and 74.937(a) (ITFS).
12. +63 dBm (Main/Booster Station EIRP) – 135.5 dB (35 mi. PL) + 20 dB (assumed gain of typical receiving antenna at
     Response Station) = -52.5 dBm
13. For thermal noise only, excluding interference; -106.2 dBm (kTB for 6 MHz) + 5 dB (NF) + 1 dB (Cable Loss) = -100.2
     dBm
14. –52.5 + 100.2 = 47.7
15. Response Stations are not licensed individually, nor are their locations known in advance of installation and operation.
     Protection for response station receivers in most 2-way MDS systems is primarily in the form of protection of the service
     area in which they are located. Specifically, at the service area outer boundary, all geographically adjacent licensees
     must engineer their systems to limit the calculated free space power flux density at any shared border with the protected
     system to a maximum value of –73 dBW/m2 (per 6 MHz bandwidth) as measured with an FCC reference antenna at a
     height of 10 meters. For pre-1997 MDS systems and for all ITFS systems, additional requirements for protection inside
     the service area are imposed in the form of permissible D/U ratios of 45 dB for co-channel interference and 0 dB for
     adjacent channel interference. See Rule Sections 21.902 (MDS), 21.909 (MDS), 21.913 (MDS), 74.903 (ITFS), 74.939
     (ITFS) and 74.985 (ITFS).




                                                               A-55
INTERIM REPORT
3G SPECTRUM STUDY
2500-2690 MHz BAND




                     THERE ARE NO APPENDICES

                          FOR SECTION 4




                               A-56
INTERIM REPORT
3G SPECTRUM STUDY
2500-2690 MHz BAND




                     APPENDICES

                        FOR

                     SECTION 5




                        A-57
                                         APPENDIX 5.1


                    TABLE 5-A: Planning Factors for Interference Protection
                                   of MDS/ITFS Response Stations
              Quantity                         Value                       Comment
Mid-frequency of 2500-2690 Band        2595 MHz              Arithmetic mean for estimation of
                                                             antenna aperture areas
Gain of Receiving Antennas of          Factor of 100, or 20  See 47 C.F.R. §§ 21.939 and
Response Stations                      dBi                   74.937(a).
Antenna Aperture of Receiving          0.162 m2              (wavelength)2 * (gain) / (4)
Systems
Desired Signal Strength for Response -83 dBW for 6 MHz       See 47 C.F.R. § 21.902(f)(6)(iii).
Stations on Periphery of Protected     channels
Service Area
Desired Power Flux Density for         -75 dBW/m2 for        Value calculated from that given in
Response Station on Periphery of       6 MHz channels        47 C.F.R. § 21.902(f)(6)(iii) and
Protected Service Area                                       antenna aperture of 0.162 m2.
Desired-to-undesired Signal Ratio for 45 dB                  See 47 C.F.R. §§ 21.902(f)(6)(iv) and
Co-channel Interference                                      74.739(d)(3)(iv).
Power Flux Density of Co-channel       -120 dBW/m2 for 6     Calculated from D/U ratio, 45 dB.
Undesired Signals Causing Harmful      MHz channels
Interference




                                              A-58
                    TABLE 5-B: Planning Factors for Interference Protection
                                       of MDS/ITFS Hubs
               Quantity                      Value                        Comment
Transmitter Power of Response         Maximum 18 dBW       See 47 C.F.R. § 21.909(g)(3).
Stations (source of MDS/ITFS          EIRP for 125 kHz     18dBW is approximately 63 W.
desired signals)                      channels
Desired Power Flux Density at         -88 dBW/m2 for 125   63 watts EIRP from response station
MDS/ITFS Hub                          kHz channels         transmitter 35 miles away
                                                  2
Max. Undesired Co-channel Power       -133 dBW/m for 125 Calculated based on 45 dB D/U ratio.
Flux Density at ITFS Hub from         kHz channels
Response Stations in Protected
Service Area
Noise Floor of Hub Receiver           -150 dBW in 125 kHz Calculated value of kTBF for hub
                                      channels             receiver noise figure of F=2.5 dB and
                                                           bandwidth B=125 kHz
                                               2
Antenna Aperture of Hub Receivers 0.0162 m                 Typical parabolic antenna with half-
                                                           power beamwidth of 30° for mid-
                                                           frequency of 2500-2690 MHz band
                                                  2
Incident Power Flux Density           -132 dBW/m           Calculated from noise floor in watts
Equivalent to Noise Floor of Hub                           and antenna aperture (line loss
Receiver                                                   neglected)
Max. Increase in Undesired Co-        0 dB                 Specified in 47 C.F.R. §§
channel Power Flux Density at ITFS                         21.909(i)(1) and 74.939(I)(1).
Hub from Transmitter outside
Protected Service Area
Max. Power Flux Density at ITFS       1 dB                 Also specified in 47 C.F.R. §§
Hub from Transmitter outside                               21.909(i)(1) and 74.939(i)(1).
Protected Service Area, Relative to
Noise Floor
Max. Undesired Co-channel Power       -139 dBW/m2 for 125 Calculated to produce 1 dB increase
Flux Density at ITFS Hub from         kHz channels         in undesired co-channel power flux
Transmitter outside Protected Service                      density (¼ of undesired power
Area                                                       already present). Within 1 dB of
                                                           limit calculated similarly from noise
                                                           floor criterion.




                                             A-59
                   Table 5-C: Calculation of Co-channel Separation Distances
                      of a 500 watt 3G Base Station to ITFS/MDS1 Stations
                                                                   Maximum              Minimum
       MDS/ITFS                                                    Undesired            Distance
   System Parameters        3G System Parameters                   3G Power            Separation3
 Protected                                             Bandwidth     Flux
 Receiver Bandwidth Modulation EIRP Bandwidth            Factor     Density2
   Type       (kHz)       Type      (dBW)    (kHz)        (dB)     (dBW/m2)          km         mi
Hub                125 CDMA             27       1250           10      -129          160.9       100
                   125 CDMA             27       3750           15      -124          160.9       100
                   125 W-CDMA           27       5000           16      -123          160.9       100
                   125 TDMA             27         30           -6      -145          160.9       100
                   125 TDMA             27        200            2      -137          160.9       100
Response
Station           6000 CDMA             27       1250           -7      -127          160.9          100
                  6000 CDMA             27       3750           -2      -122          160.9          100
                  6000 W-CDMA           27       5000           -1      -121          160.9          100
                  6000 TDMA             27         30          -23      -143          160.9          100
                  6000 TDMA             27        200          -15      -135          160.9          100

1
        To calculate the required separation distance based on free space loss, the maximum undesired
    3G power flux density that could be present at the ITFS/MDS receiver before interference would
    occur is determined. Then, the distance away from the 3G transmitter where that power flux density
    would be present is calculated. The calculations of required free space separation are made using
    the values in the columns headed "EIRP" and "Max Undesired 3G Power Flux Density." For
    example, to reduce the EIRP of 27 dBW (500 watts) to -129 dBW/m2 (7.9 microwatts/m2), the 500-
    watts of power must be spread over the surface of a sphere with a total surface area of
    500/(7.9x106) square meters. The free space column is the radius of a sphere with that surface area
    [distance = (Ptransmit/4Preceived)].
2
        The values under “Max Undesired 3G Power Flux Density” are derived from the bottom row of
    the relevant planning factors table in Appendix 4, i.e., -139 dBW/m2 for the 125 kHz channels of
    hub receivers, and -120 dBW/m2 for the 6 megahertz channels of response station receivers.
    Bandwidth factors modify these –139 and –120 values. For example, -139 dBW/m2 becomes –129
    dBW/m2 due to the 10 dB bandwidth factor for interference to ITFS/MDS 125-kHz hub receivers by
    CDMA 1250-kHz channel transmitters.
3
        As a practical matter, interference will not occur beyond the radio horizon. The rules only
    require that an interference analysis be completed if the location of a proposed station is within
    160.9 kilometers (100 miles) of an incumbent station. See 47 C.F.R. §§ 21.902 and 74.903.
    Therefore, any distance separation calculated beyond this limit is reduced to 160.9 kilometers (100
    miles) in the table.




                                                 A-60
                   Table 5-D: Calculation of Co-channel Separation Distances
                       of a 10 watt 3G Base Station to ITFS/MDS Stations
                                                                    Maximum             Minimum
       MDS/ITFS                                                     Undesired           Distance
   System Parameters        3G System Parameters                    3G Power           Separation3
 Protected                                              Bandwidth     Flux
 Receiver Bandwidth Modulation EIRP Bandwidth             Factor     Density2
   Type       (kHz)       Type      (dBW)     (kHz)        (dB)     (dBW/m2)          km         mi
Hub                125 CDMA             10       1250            10      -129          160.9       100
                   125 CDMA             10       3750            15      -124          160.9       100
                   125 W-CDMA           10       5000            16      -123          160.9       100
                   125 TDMA             10          30           -6      -145          160.9       100
                   125 TDMA             10        200             2      -137          160.9       100
Response
Station           6000 CDMA             10       1250            -7      -127          160.9         100
                  6000 CDMA             10       3750            -2      -122          160.9         100
                  6000 W-CDMA           10       5000            -1      -121          160.9         100
                  6000 TDMA             10          30          -23      -143          160.9         100
                  6000 TDMA             10        200           -15      -135          160.9         100

1
        To calculate the required separation distance based on free space loss, the maximum undesired
    3G power flux density that could be present at the ITFS/MDS receiver before interference would
    occur is determined. Then, the distance away from the 3G transmitter where that power flux density
    would be present is calculated. The calculations of required free space separation are made using
    the values in the columns headed "EIRP" and "Max Undesired 3G Power Flux Density." For
    example, to reduce the EIRP of 10 dBW (10 watts) to -129 dBW/m2 (7.9 microwatts/m2), the 10-
    watts of power must be spread over the surface of a sphere with a total surface area of 10/(7.9x106)
    square meters. The free space column is the radius of a sphere with that surface area [distance =
    (Ptransmit/4Preceived)].
2
        The values under “Max Undesired 3G Power Flux Density” are derived from the bottom row of
    the relevant planning factors table in Appendix 4, i.e., -139 dBW/m2 for the 125 kHz channels of
    hub receivers, and -120 dBW/m2 for the 6 megahertz channels of response station receivers.
    Bandwidth factors modify these –139 and –120 values. For example, -139 dBW/m2 becomes –129
    dBW/m2 due to the 10 dB bandwidth factor for interference to ITFS/MDS 125-kHz hub receivers by
    CDMA 1250-kHz channel transmitters.
3
        As a practical matter, interference will not occur beyond the radio horizon. The rules only
    require that an interference analysis be completed if the location of a proposed station is within
    160.9 kilometers (100 miles) of an incumbent station. See 47 C.F.R. §§ 21.902 and 74.903.
    Therefore, any distance separation calculated beyond this limit is reduced to 160.9 kilometers (100
    miles) in the table.




                                                 A-61
                   Table 5-E: Calculation of Co-channel Separation Distances
                          of a 3G Mobile Station to ITFS/MDS Stations
                                                                   Maximum              Minimum
       MDS/ITFS                                                    Undesired            Distance
   System Parameters        3G System Parameters                   3G Power            Separation3
 Protected                                             Bandwidth     Flux
 Receiver Bandwidth Modulation EIRP Bandwidth            Factor     Density2
   Type       (kHz)       Type     (dBW)      (kHz)       (dB)     (dBW/m2)          km         mi
Hub                125 CDMA            -10       1250           10      -129          160.9       100
                   125 CDMA            -10       3750           15      -124          148.1        92
                   125 W-CDMA          -10       5000           16      -123          127.1        79
                   125 TDMA            -10          30          -6      -145          160.9       100
                   125 TDMA            -10        200            2      -137          160.9       100
Response
Station           6000 CDMA            -10       1250           -7      -127          160.9          100
                  6000 CDMA            -10       3750           -2      -122          114.3           71
                  6000 W-CDMA          -10       5000           -1      -121           99.8           62
                  6000 TDMA            -10          30         -23      -143          160.9          100
                  6000 TDMA            -10        200          -15      -135          160.9          100
1
        To calculate the required separation distance based on free space loss, the maximum undesired
    3G power flux density that could be present at the ITFS/MDS receiver before interference would
    occur is determined. Then, the distance away from the 3G transmitter where that power flux density
    would be present is calculated. The calculations of required free space separation are made using
    the values in the columns headed "EIRP" and "Max Undesired 3G Power Flux Density." For
    example, to reduce the EIRP of -10 dBW (100 milliwatts) to -129 dBW/m2 (7.9 microwatts/m2), the
    100-milliwatts of power must be spread over the surface of a sphere with a total surface area of
    0.1/(7.9x106) square meters. The free space column is the radius of a sphere with that surface area
    [distance = (Ptransmit/4Preceived)].
2
        The values under “Max Undesired 3G Power Flux Density” are derived from the bottom row of
    the relevant planning factors table in Appendix 4, i.e., -139 dBW/m2 for the 125 kHz channels of
    hub receivers, and -120 dBW/m2 for the 6 megahertz channels of response station receivers.
    Bandwidth factors modify these –139 and –120 values. For example, -139 dBW/m2 becomes –129
    dBW/m2 due to the 10 dB bandwidth factor for interference to ITFS/MDS 125-kHz hub receivers by
    CDMA 1250-kHz channel transmitters.
3
        As a practical matter, interference will not occur beyond the radio horizon. The rules only
    require that an interference analysis be completed if the location of a proposed station is within
    160.9 kilometers (100 miles) of an incumbent station. See 47 C.F.R. §§ 21.902 and 74.903.
    Therefore, any distance separation calculated beyond this limit is reduced to 160.9 kilometers (100
    miles) in the table.




                                                 A-62
                Table 5-F: Calculation of Adjacent channel Separation Distances
                       of a 500 watt 3G Base Station to ITFS/MDS Stations
                                                                    Maximum      Minimum
       MDS/ITFS                                                     Undesired    Distance
   System Parameters         3G System Parameters                   3G Power    Separation3
 Protected                                              Bandwidth     Flux
 Receiver Bandwidth Modulation EIRP Bandwidth             Factor     Density2
   Type       (kHz)        Type     (dBW)     (kHz)        (dB)     (dBW/m2)   km        mi
Hub                125 CDMA             27        1250           10      -129   101.4        63
                   125 CDMA             27        3750           15      -124    57.9        36
                   125 W-CDMA           27        5000           16      -123    51.5        32
                   125 TDMA             27          30           -6      -145   160.9       100
                   125 TDMA             27         200            2      -137   160.9       100
Response
Station           6000 CDMA             27        1250           -7      -127   160.9       100
                  6000 CDMA             27        3750           -2      -122   160.9       100
                  6000 W-CDMA           27        5000           -1      -121   160.9       100
                  6000 TDMA             27          30          -23      -143   160.9       100
                  6000 TDMA             27         200          -15      -135   160.9       100
1
        To calculate the required separation distance based on free space loss, the maximum undesired
    3G power flux density that could be present at the ITFS/MDS receiver before interference would
    occur is determined. Then, the distance away from the 3G transmitter where that power flux density
    would be present is calculated. The calculations of required free space separation are made using
    the values in the columns headed "EIRP" and "Max Undesired 3G Power Flux Density." For
    example, to reduce the EIRP of 27 dBW (500 watts) to -129 dBW/m2 (7.9 microwatts/m2), the 500-
    watts of power must be spread over the surface of a sphere with a total surface area of
    500/(7.9x106) square meters. The free space column is the radius of a sphere with that surface area
    [distance = (Ptransmit/4Preceived)].
2
        The values under “Max Undesired 3G Power Flux Density” are derived from the bottom row of
    the relevant planning factors table in Appendix 4, i.e., -139 dBW/m2 for the 125 kHz channels of
    hub receivers, and -120 dBW/m2 for the 6 megahertz channels of response station receivers.
    Bandwidth factors modify these –139 and –120 values. For example, -139 dBW/m2 becomes –129
    dBW/m2 due to the 10 dB bandwidth factor for interference to ITFS/MDS 125-kHz hub receivers by
    CDMA 1250-kHz channel transmitters.
3
        As a practical matter, interference will not occur beyond the radio horizon. The rules only
    require that an interference analysis be completed if the location of a proposed station is within
    160.9 kilometers (100 miles) of an incumbent station. See 47 C.F.R. §§ 21.902 and 74.903.
    Therefore, any distance separation calculated beyond this limit is reduced to 160.9 kilometers (100
    miles) in the table.




                                                 A-63
                Table 5-G: Calculation of Adjacent channel Separation Distances
                       of a 10 watt 3G Base Station to ITFS/MDS Stations
                                                                    Maximum      Minimum
       MDS/ITFS                                                     Undesired    Distance
   System Parameters        3G System Parameters                    3G Power    Separation3
 Protected                                              Bandwidth     Flux
 Receiver Bandwidth Modulation EIRP Bandwidth             Factor     Density2
   Type       (kHz)       Type      (dBW)     (kHz)        (dB)     (dBW/m2)  km         mi
Hub                125 CDMA             10       1250            10      -129    14.3        8.9
                   125 CDMA             10       3750            15      -124     8.2        5.1
                   125 W-CDMA           10       5000            16      -123     7.2        4.5
                   125 TDMA             10          30           -6      -145    92.5       57.5
                   125 TDMA             10        200             2      -137    35.9       22.3
Response
Station           6000 CDMA             10       1250            -7      -127    99.3       61.7
                  6000 CDMA             10       3750            -2      -122    57.5       35.7
                  6000 W-CDMA           10       5000            -1      -121    49.7       30.9
                  6000 TDMA             10          30          -23      -143   160.9     100.0
                  6000 TDMA             10        200           -15      -135   160.9     100.0
1
        To calculate the required separation distance based on free space loss, the maximum undesired
    3G power flux density that could be present at the ITFS/MDS receiver before interference would
    occur is determined. Then, the distance away from the 3G transmitter where that power flux density
    would be present is calculated. The calculations of required free space separation are made using
    the values in the columns headed "EIRP" and "Max Undesired 3G Power Flux Density." For
    example, to reduce the EIRP of 10 dBW (10 watts) to -129 dBW/m2 (7.9 microwatts/m2), the 10-
    watts of power must be spread over the surface of a sphere with a total surface area of 10/(7.9x106)
    square meters. The free space column is the radius of a sphere with that surface area [distance =
    (Ptransmit/4Preceived)].
2
        The values under “Max Undesired 3G Power Flux Density” are derived from the bottom row of
    the relevant planning factors table in Appendix 4, i.e., -139 dBW/m2 for the 125 kHz channels of
    hub receivers, and -120 dBW/m2 for the 6 megahertz channels of response station receivers.
    Bandwidth factors modify these –139 and –120 values. For example, -139 dBW/m2 becomes –129
    dBW/m2 due to the 10 dB bandwidth factor for interference to ITFS/MDS 125-kHz hub receivers by
    CDMA 1250-kHz channel transmitters.
3
        As a practical matter, interference will not occur beyond the radio horizon. The rules only
    require that an interference analysis be completed if the location of a proposed station is within
    160.9 kilometers (100 miles) of an incumbent station. See 47 C.F.R. §§ 21.902 and 74.903.
    Therefore, any distance separation calculated beyond this limit is reduced to 160.9 kilometers (100
    miles) in the table.




                                                 A-64
                Table 5-H: Calculation of Adjacent channel Separation Distances
                         of a 3G Mobile Station to ITFS/MDS Stations
                                                                  Maximum        Minimum
       MDS/ITFS                                                   Undesired      Distance
   System Parameters       3G System Parameters                   3G Power      Separation3
 Protected                                            Bandwidth     Flux
 Receiver Bandwidth Modulation EIRP Bandwidth           Factor     Density2
   Type       (kHz)      Type     (dBW)      (kHz)       (dB)     (dBW/m2)    km         mi
Hub                125 CDMA           -10       1250           10      -129       1.4        0.9
                   125 CDMA           -10       3750           15      -124       0.8        0.5
                   125 W-CDMA         -10       5000           16      -123       0.6        0.4
                   125 TDMA           -10          30          -6      -145       9.3        5.8
                   125 TDMA           -10        200            2      -137       3.5        2.2
Response
Station           6000 CDMA           -10       1250           -7      -127      10.0        6.2
                  6000 CDMA           -10       3750           -2      -122       5.8        3.6
                  6000 W-CDMA         -10       5000           -1      -121       5.0        3.1
                  6000 TDMA           -10          30         -23      -143      64.2       39.9
                  6000 TDMA           -10        200          -15      -135      24.8       15.4
1
        To calculate the required separation distance based on free space loss, the maximum undesired
    3G power flux density that could be present at the ITFS/MDS receiver before interference would
    occur is determined. Then, the distance away from the 3G transmitter where that power flux density
    would be present is calculated. The calculations of required free space separation are made using
    the values in the columns headed "EIRP" and "Max Undesired 3G Power Flux Density." For
    example, to reduce the EIRP of -10 dBW (100 milliwatts) to -129 dBW/m2 (7.9 microwatts/m2), the
    100-milliwatts of power must be spread over the surface of a sphere with a total surface area of
    0.1/(7.9x106) square meters. The free space column is the radius of a sphere with that surface area
    [distance = (Ptransmit/4Preceived)].
2
        The values under “Max Undesired 3G Power Flux Density” are derived from the bottom row of
    the relevant planning factors table in Appendix 4, i.e., -139 dBW/m2 for the 125 kHz channels of
    hub receivers, and -120 dBW/m2 for the 6 megahertz channels of response station receivers.
    Bandwidth factors modify these –139 and –120 values. For example, -139 dBW/m2 becomes –129
    dBW/m2 due to the 10 dB bandwidth factor for interference to ITFS/MDS 125-kHz hub receivers by
    CDMA 1250-kHz channel transmitters.
3
        As a practical matter, interference will not occur beyond the radio horizon. The rules only
    require that an interference analysis be completed if the location of a proposed station is within
    160.9 kilometers (100 miles) of an incumbent station. See 47 C.F.R. §§ 21.902 and 74.903.
    Therefore, any distance separation calculated beyond this limit is reduced to 160.9 kilometers (100
    miles) in the table.




                                                 A-65
                                          APPENDIX 5.2

          Feasibility Study on Spectrum Sharing between Fixed Terrestrial
             Wireless Services and proposed Third Generation Mobile
                        Services in the 2500-2690 MHz Bands

                         George W. Harter, Director of Broadcast Engineering, MSI
                 for the Sprint Broadband Wireless Group, WorldCom Wireless Solutions,
       Nucentrix Broadband Networks, and the Wireless Communications Association International.

    (Used and reproduced with permission of the Wireless Communications Association International.)

ABSTRACT

         The frequency bands from 1710-1885 MHz and 2500-2690 MHz have been identified at
WRC-2000 as spectrum for consideration in the implementation of proposed third generation
(“3G”) mobile services internationally. However, it was recognized that full utilization of any
identified band might not be possible because of domestic uses in certain countries. In the US,
the bands 2150-2162 and 2500-2690 MHz are utilized extensively for fixed wireless services
commonly know as Multichannel Multipoint Distribution Services (“MMDS”) and Instructional
Television Fixed Services (“ITFS”). These point-to-multipoint services have been in existence
for over 40 years and have numerous transmission and reception points throughout the country.
 Historically utilized for video distribution, these services have undergone important regulatory
changes over the past several years to allow the industry to evolve into a bi-directional digital
high speed Internet access service. The first regulatory filing period has now concluded and
implementation of these broadband data services on a wide scale basis has begun.

         Co-frequency utilization by existing and planned MMDS/ITFS services and proposed 3G
services will not be possible because of unavoidable and unacceptable interference between
the two services. Interference from 3G services into MMDS/ITFS will be severe because of (1)
the sensitivity of the MMDS/ITFS receivers (both hub and CPE) based on the need to utilize
higher order modulation techniques, (2) the commercial necessity of utilizing economical
receive antennas and the inability to discriminate the mobile 3G services for interference
isolation, (3) the already compromised interference environment created by existing levels of
co-channel interference between neighboring markets and (4) the need for high degrees of
frequency reuse within urban markets to meet the expected capacity demands. Likewise,
interference from MMDS/ITFS services into 3G services will be severe because of (1) the use
of omnidirectional mobile receive antennas with no ability to discriminate, (2) the high power
levels of the fixed services at the hub broadcast over a wide or omnidirectional area, (3) the
power levels of the CPE return path transmissions and (4) the high probability that 3G receivers
will be in close proximity to either MMDS/ITFS hub or CPE sites.

MMDS/ITFS SYSTEM OPERATION

        The architectures for MMDS/ITFS systems vary based on the service offering, the
population of the market and the terrain characteristics of the market area. Currently there are
four basic service offerings: analog television, digital television, unidirectional digital data and
bi-directional digital data. The architecture that will be utilized in many second and third tier
markets to deliver all of these services is a single cell or “super cell” configuration. This
architecture utilizes a single transmit site located on a high building or tower to cover a large


                                                 A-66
area (up to 35 miles in radius.) This architecture may utilize an omnidirectional or broad
beamwidth cardioid antenna with power levels as high as the FCC rules will allow. In certain
markets where terrain or foliage is severe, repeaters may be used to fill in areas of poor
coverage. These repeaters rebroadcast all channels on the same frequencies as they are
received. Therefore, self-interference can only be controlled by isolation between service areas
created by terrain or other obstructions.

         Cellular architectures are being developed primarily for larger markets where the
expected demand for broadband data can support the increased costs. This architecture
utilizes existing buildings or towers located in close proximity to potential customer locations
with the minimum height and power necessary to achieve the path reliability throughout the
desired coverage area. Interference is controlled by careful frequency planning utilizing
polarization, sector geometry and receive antenna isolation.

Analog Television

        A majority of the analog television MMDS/ITFS implementations in the US utilize an
architecture where a single high power transmitter is located on a tall transmit site in or near a
populated area. In urban environments, this site is usually a tall building or tower in or near the
center of population. The transmit antenna pattern will typically be omnidirectional or a wide
cardioid. In more rural markets the transmit site may be removed from the population center in
order to take advantage of high terrain feature or an existing tower and a more directional
cardioid antenna would be utilized to concentrate coverage in the desired area. The maximum
EIRP allowed by the FCC is 2000 watts peak analog power when an omnidirectional transmit
antenna is utilized. Slightly higher power levels may be allowed in certain cases when cardioid
antennas are utilized. Typical EIRP’s are in the 100 –1000 watt range. Either horizontal or
vertical polarization is allowed.

       Receive sites utilize directional antennas of various sizes and gains dependent upon
distance from the transmit site and the quality of the propagation path to the transmit site.
These antennas range in gain from 12 to 27 dBi and vary in size from approximately 0.2 – 1.2
meters in diameter. A copy of the antenna patterns for several representative antennas is
attached as Attachment 1. The height of these antennas must be sufficient to achieve an
unobstructed or very nearly unobstructed propagation path to the transmit site. Because of size
and cost, the smaller antennas are practical for deployment on a broad scale at single family
homes while the large antennas tend to be utilized at multi-dwelling units or businesses.

         Analog television signals require a very high carrier-to-noise ratio (“C/N”) at the receive
site in order to produce a high quality video signal. Degradations in received signal strength
due to obstructed paths or interference will very quickly manifest themselves as degraded
picture quality. Current FCC rules require the carrier-to-interference ratio (“C/I”) for incumbent
stations to be maintained at 45 dB for co-channel stations operating in neighboring markets.
This level of protection must be maintained at all unobstructed areas in a protected service area
defined as a 35 mile radius circle around the desired transmit site. This level of co-channel
interference protection will result in a subjective picture quality of grade 3 based on the ITU/R
Recommendation 500 rating scale. This figure of merit categorizes the impairment caused by
the interference as “slightly annoying.”




                                               A-67
Digital Television

        Digital television systems utilize the same supercell architecture as analog television
systems with similar technical configurations for the transmit and receive site equipment.
Transmit power limits remain the same but the EIRP is now referenced to average digital
power. The major difference is in the practical interference protection requirement. Although
the current FCC rules require the same 45 dB co-channel protection as analog systems, digital
systems can tolerate more interference. The modulation technique employed in digital TV
MMDS/ITFS systems is 64-QAM with forward error correction included. This modulation allows
receivers to tolerate lower C/I than the 45 dB FCC analog television requirement.

Data Transmissions

        Data systems will utilize one of two different architectures depending on the location of
the market, the number of potential subscribers, and the desired service offerings. In second
and third tier markets where the number of potential subscribers and the desired service
offering can only support a single transmit site, a supercell architecture is employed. The
technical configurations for the downstream transmissions are the same as an analog or digital
television system as described above with the addition of sectorization at the antenna to
improve frequency reuse and capacity. These systems currently utilize various modulation
techniques including QPSK, 64-QAM, VOFDM and TDMA or CDMA multiplexing techniques.

        Upstream transmissions are accomplished at a subscriber site through a transverter,
typically utilizing the same antenna for transmission as reception. These antennas have the
same gain range as described previously of 12 to 27 dBi. Many of the transverters and
antennas are built as integrated units. The upstream receive antennas for integrated units will
have typical gains in the 10 to 24 dBi range.

       In larger markets where the potential subscriber base can support multiple cell sites,
frequency reuse is necessary to meet the capacity demands. In order to implement an
aggressive frequency reuse plan, a cellular architecture must be employed. The technical
characteristics will be similar to those discussed previously with downstream and upstream
power levels in the range of 1 – 100 watts EIRP.

INTERFERENCE INTO MMDS/ITFS SYSTEMS

       The interference potential from 3G mobile units to the fixed receive sites of an
MMDS/ITFS system operating in the same frequency band is real but difficult to predict. These
mobile units will be deployed in mass with expected high densities of transmitters. A simulation
methodology has to be created in order to estimate the amount of interference power a system
could be generating in the area of MMDS/ITFS receive sites. The development of this
simulation methodology is beyond the scope of this paper.

       However, predicting the potential for interference from 3G hubs or base stations to
MMDS/ITFS receivers is a more manageable task. This potential for interference can best be
described by first calculating the predicted level of interference between typical 3G and
MMDS/ITFS system configurations and then determining a minimum required separation
distance between systems to reduce the predicted interference to manageable levels.
MMDS/ITFS receive sites can exist at subscriber locations for downstream transmissions or at



                                              A-68
hub locations for upstream transmissions. If interference is predicted to be small, then the
minimum separation distance will be small and systems can coexist. However, if the predicted
interference is severe and the separation distance is predicted to be large, the potential for
widespread interference is large and coexistence becomes impossible.




                                                       d1



                                                               d3


                                                                              MMDS/
                                  d2
                                                                             ITFS Hub

               MMDS/ITFS
               Subscriber




                                              3G Hub



        The above diagram depicts the potential for interference from a 3G hub to MMDS/ITFS
receive sites. It is assumed from a practical standpoint that 3G hubs will be distributed around a
market area in a way that is similar to the distribution of current PCS and cellular towers,
resulting in 3G hubs being located in close proximity (i.e., on the order of 500 - 1000 feet) to
many homes and businesses that are potential subscribers to services offered by MMDS/ITFS
systems. As shown below, however, the calculated minimum tolerable separation distances for
coexistence between 3G hubs and MMDS/ITFS receive locations is on the order of tens of
miles which would result in significant potential for harmful interference to both analog and
digital MMDS/ITFS services.

Analog Television Receive Sites

         Assuming the maximum acceptable level of co-channel interference from a 3G mobile
unit or hub to a MMDS/ITFS analog television receive site is 45 dB (C/I), the expected degree
of interference to typical system configurations from one or more 3G hubs can be calculated.
This level of interference protection is currently required by the Commission in the rules
covering MMDS and ITFS operation.

       Assume for the first scenario a typical MMDS/ITFS transmit site configuration with an
omnidirectional transmit antenna operating with an EIRP of 100 watts. The transmit antenna


                                              A-69
height will be placed at 90 meters AGL. The MMDS/ITFS receive site will use a 12 dBi antenna
and will be located 1 to 35 miles from the transmit site.

         The 3G hub is assumed to be operating with 100 watts of average EIRP spread across
a 4.5 MHz bandwidth. The 3G hub is also assumed to be broadcasting omnidirectional. This
assumption may not be reasonable on a single frequency, however, if all of the frequencies
used by the various 3G sectors are co-channel with the MMDS/ITFS frequencies then the study
will represent a composite of all the potential for interference across the band. The 3G hub is
assumed to be located approximately 8 miles away from the MMDS/ITFS hub. This distance is
very conservative and presents a scenario where 3G services have the best chance of not
creating interference to MMDS/ITFS services.

        The results of the study are shown below in Figure 1. The various colored regions
represent different levels of predicted interference. An area that meets or exceeds the 45 dB
requirement appears on the figure in green. As the study shows, a majority of the 35 mile
service area would receive harmful interference from a single 3G hub. This area of interference
represents approximately 60% of the total MMDS/ITFS potential service area. In fact, a
majority of the interference area experiences interference levels of 20 dB or greater.


                   3G Hub Interference to MMDS/ITFS

                                                                    35 Mile Radius




        System Parameters                           MMDS/ITFS Hub
         MMDS/ITFS Hub:
          EIRP - 50 dBmW          3G Hub
          AGL - 90 m
                                                

         3G Hub:
           EIRP - 50 dBmW                  
           AGL - 30 m

                                                                                     C/I Study
                                                                                     D/U Ratio
                                                                                     > 45 dB
                                                                                      30 to 45 dB
                                                                                      20 to 30 dB
                                                                                       0 to 20 dB
                                                                                     -15 to 0 dB
                                                                                     < -15 dB



          0           10     20

                     miles




       Figure 1 - Interference from a single 3G hub to an MMDS/ITFS service area.

        A minimum separation distance between a 3G transmitter and an MMDS/ITFS receive
site can be calculated using the same assumptions regarding system operation specified
above. Antenna discrimination will not be considered as there will certainly be locations


                                               A-70
oriented towards both the 3G and MMDS hub. The table below shows the required separation
distances in order to reduce the interference shown above to acceptable levels. As one can
see, the required separation distances are calculated to be in miles, not feet. In fact, all of the
distances calculated are well beyond the radio horizon for normal 4/3 earth curvature.
Therefore, the actual separations will be a function of the radio horizon and the excess path
attenuation generated by terrain and obstruction blockage. Therefore, coexistence between 3G
services and analog television services is impossible for this scenario.

          Distance                                  Required
          between                       MMDS        3G Rx Lvl                       Required
          MMDS Tx and      Path Loss    Rx LVL      for 45 dB     Discrimination    Separation
          Rx (miles)       (dB)         (dBm)       C/I (dBm)     (dB)              (miles)
                      1         104.9       -54.9         -99.9                 0      177.8 **
                      2         110.9   -60.9206      -105.921                  0      355.7 **
                      3         116.9   -66.9412      -111.941                  0      711.3 **
                      4         123.0   -72.9618      -117.962                  0    1422.6 **
                     16         129.0   -78.9824      -123.982                  0    2845.2 **
                     32         135.0    -85.003      -130.003                  0    5690.5 **

** These distances are beyond the radio horizon and will therefore be limited by the radio
horizon.

Table 1. Required Separation Distance between 3G Base Station and MMDS/ITFS Analog
Television Rx Sites

       A similar prediction can be performed for multiple 3G hubs in the same 35 mile radius
service area as shown in the Figure 2 below. These hubs are assumed to be operating on the
same frequency as the MMDS/ITFS hub. This is a reasonable assumption since the hubs are
separated by a relatively large distance. The interference levels become significantly worse,
increasing the interference zone to 80-85% of the available service area.




                                                A-71
                   3G Hub Interference to MMDS/ITFS

                                                                            35 Mile Radius




                                                      3G Hub


                                                  
          System Parameters                               MMDS/ITFS Hub
           MMDS/ITFS Hub:
            EIRP - 50 dBmW           3G Hub
            AGL - 90 m                                            3G Hub
           3G Hub:
             EIRP - 50 dBmW                                
             AGL - 30 m

                                                                                             C/I Study
                                                                                             D/U Ratio
                                                                                             > 45 dB
                                                                                              30 to 45 dB
                                                                                              20 to 30 dB
                                                                                               0 to 20 dB
                                                                                             -15 to 0 dB
                                                                                             < -15 dB



           0          10      20

                     miles




Figure 2 - Interference from multiple 3G hubs to MMDS/ITFS Analog Television Rx Sites


Data Transmissions

        Similar calculations can be performed for an MMDS/ITFS high-speed data system.
Assume the same technical characteristics for the system as in the previous analysis with the
exception of lowering the MMDS/ITFS hub site to 30 meters as might be the case in a
cellularized digital data system. In addition, the service area will be reduced to 15 miles in
radius. Also, the interference protection requirement will change based on the digital
transmission and the modulation technique. The lower order modulation techniques will
tolerate higher levels of interfering signal than the higher order techniques. Therefore, several
different modulation techniques will be analyzed.

         The current technologies being utilized in MMDS/ITFS data transmission systems utilize
various modulation techniques and densities. The highest order modulation technique currently
utilized is 64-QAM. This modulation technique requires a minimum C/I+N of 22-24dB. Lower
order modulation techniques are possible as well, with a minimum C/I+N requirement of 9-11
dB. These C/I+N values represent theoretical limits and do not incorporate additional margins
for practical equipment operation or system design margins.

      Below is an area wide interference study for MMDS/ITFS data transmission and a single
3G hub. Again, the service area is significantly reduced because of the 3G hub interference


                                                  A-72
into CPE receive sites. For the higher order modulation techniques such as 64-QAM, the area
of unacceptable interference is approximately 60% of the total potential service area. While
lower order modulation techniques would reduce the percentage somewhat, there would be a
severe economic penalty in loss of capacity.

        The table below shows the minimum separation distance requirements for QPSK
through 64-QAM modulation techniques. The same assumptions regarding power levels were
used as in the previous calculations. These calculations are applicable to supercell or cellular
architectures. Again, the results show the required separation distances to be in miles, not feet.

        Antenna discrimination could improve these conditions at MMDS/ITFS hub locations.
However, the probability that MMDS/ITFS hubs and 3G hubs would have unobstructed
propagation paths to each other is high. In these situations the ability to use discrimination will
be diminished if not completely eliminated. Therefore, co-frequency operation is again not
feasible between the two services.

        Likewise, Figure 4 contains an interference study with multiple 3G hubs causing
interference to a single MMDS/ITFS data reception system. For higher order modulation
densities, the area of interference is approximately 85% of the total potential service area.
Again, the area of interference could be reduced somewhat by use of lower order modulation
techniques, but at a significant reduction in overall capacity.


                   3G Hub Interference to MMDS/ITFS
                             15 Mile Radius




                                                             MMDS/ITFS Hub

         System Parameters
          MMDS/ITFS Hub:
           EIRP - 50 dBmW
           AGL - 30 m

          3G Hub:                                       
            EIRP - 50 dBmW
            AGL - 30 m                   3G Hub


                                                                                 C/I Study
                                                                                  D/U Ratio

                                                                                  > 45 dB
                                                                                   30 to 45 dB
                                                                                   20 to 30 dB
                                                                                    0 to 20 dB
                                                                                  -15 to 0 dB
                                                                                  < -15 dB




                              0   2 .5      5

                                  miles




Figure 3 - Interference from a single 3G hub to MMDS/ITFS data receive sites




                                                      A-73
       .

Distance      MMDS
between       Rx LVL
MMDS          @ Input
Tx and Path   to                                                     Rx Ant
Rx       Loss Antenna Required 3G Rx Lvl for Min C/I with            Discri
(miles) (dB)  (dBm) FEC (dBm)                                        m (dB) Required Separation (miles)
                                                256-                                                  256-
                      QPSK 16-QAM 64-QAM QAM                                QPSK 16-QAM 64-QAM QAM
1       104.9 -54.9   -63.9   -71.2   -77.2     -83.2                0      2.8     6.5      13.0     26.0
2       110.9 -60.9   -69.9   -77.2   -83.2     -89.2                0      5.6     13.1     26.1     52.0
4       116.9 -66.9   -75.9   -83.2   -89.2     -95.2                0      11.3    26.1     52.1     104.0
8       123.0 -73.0   -82.0   -89.3   -95.3     -101.3               0      22.5    52.3     104.3    208.0
16      129.0 -79.0   -88.0   -95.3   -101.3 -107.3                  0      45.1    104.5    208.5    416.0
32      135.0 -85.0   -94.0   -101.3 -107.3 -113.3                   0      90.2    209.0    417.0    832.1
Table 2. Required Separation Distance between 3G Base Station and MMDS/ITFS Data Rx
Site




                    3G Hub Interference to MMDS/ITFS
                               15 Mile Radius

                                                            3G Hub
                                                        


                                                                      MMDS/ITFS Hub

           System Parameters
            MMDS/ITFS Hub:
             EIRP - 50 dBmW
             AGL - 30 m

            3G Hubs:                                           
              EIRP - 50 dBmW
              AGL - 30 m                   3G Hub
                                                                            3G Hub

                                                                       
                                                                                             C/I Study
                                                                                             D/U Ratio

                                                                                             > 45 dB
                                                                                              30 to 45 dB
                                                                                              20 to 30 dB
                                                                                               0 to 20 dB
                                                                                             -15 to 0 dB
                                                                                             < -15 dB




                                0   2 .5      5

                                    miles




Figure 4 - Interference from multiple 3G hubs to MMDS/ITFS data receive sites.




                                                             A-74
CONCLUSIONS


        The studies presented in this paper have shown that it is impossible for 3G services to
coexist in the same frequency band with MMDS/ITFS fixed services. The level of co-channel
interference from 3G hubs alone is sufficient to devastate the commercial operation of a
MMDS/ITFS system. If the potential for interference from 3G hubs to MMDS/ITFS hubs and
from 3G mobile units to MMDS/ITFS hubs and CPE’s is added into the equation, the
MMDS/ITFS system will be completely unusable. In addition, the studies in this paper have
been extremely conservative with regard to the operational characteristics of the postulated 3G
system. For example, there typically would be significantly more 3G hubs in an area than the
one to three used in these studies.




                                             A-75
             Attachment 1 to Appendix 5.3

   Representative MMDS/ITFS Receive Antenna Pattern




Representative MMDS/ITFS Omni Transmit Antenna Patterns




                         A-76
                                            APPENDIX 5.3
                            MAPS OF ITFS and MDS CHANNEL ASSIGNMENTS



                                          ITFS/MDS Channels in the 2500-2690 MHz band

      1      2       A1 B1 A2 B2 A3 B3 A4 B4 C1 D1 C2 D2 C3 D3 C4 D4 E1 F1 E2 F2 E3 F3 E4 F4 G1 H1 G2 H2 G3 H3 G4 I

     MDS                                       ITFS Channels                                                     MDS Channels                       Interleaved               R
            2160/2




                                                                                                                                                                                   MHz
     2150




                     2500




                                                                                                      2596




                                                                                                                                                                            2686
                                12
                                     18
                                          24
                                               30
                                                    36
                                                         42
                                                              48
                                                                   54
                                                                        60
                                                                             66
                                                                                  72
                                                                                       78
                                                                                            84
                                                                                                 90




                                                                                                                     14
                                                                                                                          20
                                                                                                                               26
                                                                                                                                    32
                                                                                                                                         38
                                                                                                                                              44
                                                                                                                                                   50
                                                                                                                                                        56
                                                                                                                                                             62
                                                                                                                                                                  68
                                                                                                                                                                       74
                                                                                                                                                                            80
                            6




                                                                                                             2
                                                                                                                 8
Source of Assignment Data:

         The maps shown in the Interim Report and Appendices were generated using data extracted from
the Mass Media Bureau‟s Broadband Licensing System (BLS) on November 6, 2000. Daily BLS extracts
can be found at: <ftp://ftp.fcc.gov/Bureaus/Mass_Media/Databases/bls/bls.zip> (file size: 5.5 Mb). The
data is updated daily at 11:45 PM.


Spectrum Analysis Tools:

        Commission staff, in order to make use of web published assignment data, have written computer
programs that: 1) convert web exported license and application data into a database (MS Access) format
for conducting spectrum usage studies (CnvBls) and 2) map/plots license and application data (MffTools).
 These programs are available for downloading from Commission‟s web site at
<http://www.fcc.gov/oet/info/software/suss/>.


Map Key:

   Gray circle - represents the protected service area (PSA) of the main ITFS (or MDS) transmitter site
    on Channel Groups A, B, C, D or G.

   White circle - represents the PSA of the main MDS (or ITFS) transmitter site on Channel Groups E,
    F or H. Note: Main MDS transmitters associated with an auctioned BTA do not have PSAs.

   Gray shaded area - represents the auctioned BTAs for Channel Groups E, F and H.

   Red Line - represents the path between a main ITFS transmitter site and a registered receiver site.

   Blue Diamond – represents a main or booster ITFS or MDS transmitter site around which multiple
    unregistered receive sites are located.

   Green Diamond - represents an ITFS or MDS hub receiver site around which unregistered subscriber
    stations are located.


                                                                                   A-77
Note:      License data shown on the maps includes both licenses and construction permits.
           Application data includes applications which have been accepted for filing and those that
           have been receive but have not yet been accepted for filing (tendered)

        The first three maps show a composite of all licenses and applications across the entire
2500 – 2690 MHz band. The remaining 32 maps show only licenses on a channel by channel basis.




                                                A-78
A-79
A-80
A-81
A-82
A-83
A-84
A-85
A-86
A-87
A-88
A-89
A-90
A-91
A-92
A-93
A-94
A-95
                               APPENDIX 5.4
           ITFS/MDS ASSIGNMENTS FOR MAJOR METROPOLITAN AREAS

The following table indicates the licensed data for the 50 most populated major metropolitan areas within
the United States. An “L” indicates that there is at least one licensed ITFS/MDS main stations located
within 56.3 kilometers (35 miles) of the center city geographic coordinates. When the database contained
no licensed main station that close to the center city coordinates, the closest licensed main station is
noted by its distance in kilometers from the center city coordinates. A “T” indicates applications
tendered for filing.

   Channels       New York     Los Angeles      Chicago     Philadelphia     Detroit        Boston
       1             L              L              L             L             L              L
     2/2A            L              L              L             L             L              L
      A1             L              L              L             L             L              L
      A2             L              L              L             L             L              L
      A3             L              L              L             L             L            85 km
      A4             L              L              L             L             L            85 km
      B1             L              L              L             L             L              L
      B2             L              L              L             L             L              L
      B3             L              L              L             L             L              L
      B4             L              L              L             L             L              L
      C1             L              L              L             L             L              L
      C2             L              L              L             L             L              L
      C3             L              L              L             L             L              L
      C4             L              L              L             L             L              L
      D1             L              L              L             L             L              L
      D2             L              L              L             L             L              L
      D3             L              L              L             L             L              L
      D4             L              L              L             L             L              L
      E1             L              L              L             L             L              L
      E2             L              L              L             L             L              L
      E3             L              L              L             L             L              L
      E4             L              L              L             L             L              L
      F1             L              L              L             L             L              L
      F2             L              L              L             L             L              L
      F3             L              L              L             L             L              L
      F4             L              L              L             L             L              L
      G1             L              L              L             L           79 km            L
      G2             L              L              L             L           79 km            L
      G3             L              L              L             L             L              L
      G4             L              L              L             L             L              L
      H1             L              L              L             L             L              L
      H2             L              L              L             L             L              L
      H3             L              L              L           83 km           L              L




                                                  A-96
Channels     San       Washington,   Dallas-    Houston   St. Louis   Miami
           Francisco      D.C.     Fort Worth
    1         L            L            L         L         L           L
  2/2A        L            L            L         L         L         89 km
   A1         L          58 km          L         L       104 km        L
   A2         L          58 km          L         L       104 km        L
   A3         L          58 km          L         L       104 km        L
   A4         L            L            L         L       104 km        L
   B1         L            L            L         L         L           L
   B2         L            L            L         L         L           L
   B3         L            L            L         L         L           L
   B4         L            L            L         L         L           L
   C1         L            L            L         L         L           L
   C2         L            L            L         L         L           L
   C3         L            L            L         L         L           L
   C4         L            L            L         L         L           L
   D1         L            L            L         L         L           L
   D2         L            L            L         L         L           L
   D3         L            L            L         L         L           L
   D4         L            L            L         L         L           L
   E1         L            L            L         L         L           L
   E2         L            L            L         L         L           L
   E3         L            L            L         L         L           L
   E4         L            L            L         L         L           L
   F1         L            L            L         L         L           L
   F2         L            L            L         L         L           L
   F3         L            L            L         L         L           L
   F4         L            L            L         L         L           L
   G1         L            L            L         L         L           L
   G2         L            L            L         L         L           L
   G3         L            L            L         L         L           L
   G4         L            L            L         L         L           L
   H1         L            L            L         L         L           L
   H2         L            L            L         L         L           L
   H3         L            L            L         L         L           L




                                      A-97
                                    Minneapolis
Channels   Pittsburgh   Baltimore    St. Paul     Cleveland   Atlanta   San Diego
    1           L           L            L            L          L          L
  2/2A       74 km          L            L         101 km        L          L
   A1           L           L            L            L          L          L
   A2           L           L            L            L          L          L
   A3           L           L            L            L          L          L
   A4           L           L            L            L          L          L
   B1           L           L            L            L          L          L
   B2           L           L            L            L          L          L
   B3           L           L            L            L          L          L
   B4           L           L            L            L          L          L
   C1           L           L            L            L          L          L
   C2           L           L            L            L          L          L
   C3           L           L            L            L          L          L
   C4           L           L            L            L          L          L
   D1           L           L            L            L          L          L
   D2           L           L            L            L          L          L
   D3           L           L            L            L          L          L
   D4           L           L            L            L          L          L
   E1           L           L            L            L          L        72 km
   E2           L           L            L            L          L        72 km
   E3           L           L            L            L          L        72 km
   E4           L           L            L            L          L        72 km
   F1           L           L            L            L          L          L
   F2           L           L            L            L          L          L
   F3           L           L            L            L          L          L
   F4           L           L            L            L          L          L
   G1           L           L            L            L          L          L
   G2           L           L            L            L          L          L
   G3           L           L            L            L          L          L
   G4           L           L            L            L          L          L
   H1           L           L            L            L          L          L
   H2           L           L            L            L          L          L
   H3           L           L            L            L          L          L




                                       A-98
Channels   Denver   Seattle   Milwaukee   Tampa   Cincinnati   Kansas City
    1        L         L          L         L         L            L
  2/2A       L         L          L         L         L            L
   A1        L         L          L         L         L            L
   A2        L         L          L       53 km       L            L
   A3        L         L          L       53 km       L            L
   A4        L         L          L         L         L            L
   B1        L         L          L         L         L            L
   B2        L         L          L         L         L            L
   B3        L         L          L         L         L            L
   B4        L         L          L         L         L            L
   C1        L         L          L         L         L            L
   C2        L         L          L         L         L            L
   C3        L         L          L         L         L            L
   C4        L         L          L         L         L            L
   D1        L         L          L         L         L            L
   D2        L         L          L         L         L            L
   D3        L         L          L         L         L            L
   D4        L         L          L         L         L            L
   E1        L         L          L         L         L            L
   E2        L         L          L         L         L            L
   E3        L         L          L         L         L            L
   E4        L         L          L         L         L            L
   F1        L         L          L         L         L            L
   F2        L         L          L         L         L            L
   F3        L         L          L         L         L            L
   F4        L         L          L         L         L            L
   G1        L      124 km        L         L       65 km          L
   G2        L      124 km        L         L       65 km          L
   G3        L      124 km        L         L       65 km          L
   G4        L      124 km        L         L       65 km          L
   H1        L       97 km        L         L       72 km          L
   H2        L       97 km        L         L       72 km          L
   H3        L         L          L         L       72 km          L




                                A-99
                                                           New
Channels   Buffalo   Phoenix   San Jose   Indianapolis   Orleans   Portland
    1        L         L          L            L            L         L
  2/2A       L         L          L            L            L         L
   A1        L         L          L            L            L         L
   A2        L         L          L            L            L         L
   A3        L         L          L            L            L         L
   A4        L         L          L            L            L         L
   B1        L         L          L            L            L         L
   B2        L         L          L            L            L         L
   B3        L         L          L            L            L         L
   B4        L         L          L            L            L         L
   C1        L         L          L            L            L         L
   C2        L         L          L            L            L         L
   C3        L         L          L            L            L         L
   C4        L         L          L            L            L         L
   D1        L         L        61 km          L            L         L
   D2        L         L        61 km          L            L         L
   D3        L         L        61 km          L            L         L
   D4        L         L        61 km          L            L         L
   E1        L         L          L            L            L         L
   E2        L         L          L            L            L         L
   E3        L         L          L            L            L         L
   E4        L         L          L            L            L         L
   F1        L         L          L            L            L         L
   F2        L         L          L            L            L         L
   F3        L         L          L            L            L         L
   F4        L         L          L            L            L         L
   G1        L         L          L            L            L         L
   G2        L         L          L            L            L         L
   G3        L         L          L            L            L         L
   G4        L         L          L            L            L         L
   H1        L         L          L            L            L         L
   H2        L         L          L            L            L         L
   H3        L         L        61 km          L          81 km       L




                                A-100
                                   San     Rochester,
Channels   Columbus   Hartford   Antonio      NY        Sacramento   Memphis
    1          L         L          L          L             L          L
  2/2A         L         L          L          L             L          L
   A1          L         L        62 km        L             L          L
   A2          L         L        62 km        L             L          L
   A3          L         L        62 km        L             L          L
   A4          L         L        62 km        L             L          L
   B1          L       53 km        L          L             L        66 km
   B2          L       53 km        L          L             L        66 km
   B3          L       53 km        L          L             L        66 km
   B4          L       53 km        L          L             L        66 km
   C1          L         L          L       119 km           L          L
   C2          L         L          L       119 km           L          L
   C3          L         L          L       119 km           L          L
   C4          L         L          L       119 km           L          L
   D1          L         L          L          L           75 km      66 km
   D2          L         L          L          L           75 km      66 km
   D3          L         L          L          L           56 km      66 km
   D4          L         L          L          L             L        66 km
   E1          L         L          L       108 km           L          L
   E2          L         L          L       108 km           L          L
   E3          L         L          L       108 km           L          L
   E4          L         L          L       108 km           L          L
   F1          L         L          L          L             L          L
   F2          L         L          L          L             L          L
   F3          L         L          L          L             L          L
   F4          L         L          L          L             L          L
   G1          L         L          L          L             L          L
   G2          L         L          L          L             L          L
   G3          L       73 km        L          L             L          L
   G4          L       73 km        L          L             L          L
   H1          L         L          L          L             L          L
   H2          L         L          L          L             L          L
   H3          L         L          L          L             L          L




                                 A-101
Channels   Louisville   Providence   Salt Lake   Dayton   Birmingham Bridgeport
    1         L             L            L         L           L         L
  2/2A        L             L            L         L           L         L
   A1       118 km          L            L         L           L         L
   A2       118 km          L            L         L           L         L
   A3       118 km          L            L         L           L         L
   A4       118 km          L            L         L           L         L
   B1         L             L            L         L           L         L
   B2         L             L            L         L           L         L
   B3         L             L            L         L           L         L
   B4         L             L        VACANT        L           L         L
   C1         L             L            L       68 km         L       65 km
   C2         L             L            L       68 km         L       65 km
   C3         L             L            L       68 km         L         L
   C4         L             L            L       68 km         L         L
   D1         L             L         T-28 km    60 km         L         L
   D2         L             L         T-28 km    60 km         L         L
   D3         L             L         T-28 km    60 km         L         L
   D4         L             L         T-28 km    60 km         L         L
   E1         L             L            L         L           L         L
   E2         L             L            L         L           L         L
   E3         L             L            L         L           L         L
   E4         L             L            L         L           L         L
   F1         L             L            L         L           L       63 km
   F2         L             L            L         L           L       63 km
   F3         L             L            L         L           L       63 km
   F4         L             L            L         L           L       63 km
   G1         L             L            L         L           L         L
   G2         L             L            L         L           L         L
   G3         L             L            L         L           L         L
   G4         L             L            L         L           L         L
   H1         L             L            L         L         36 km     65 km
   H2         L             L            L         L           L       65 km
   H3         L             L            L         L           L         L




                                      A-102
                              Oklahoma
Channels   Norfolk   Albany     City     Nashville   Toledo   New Haven
    1        L         L          L         L          L          L
  2/2A       L         L          L         L          L          L
   A1        L         L          L         L          L          L
   A2        L         L          L         L          L          L
   A3        L         L          L         L          L          L
   A4        L         L          L         L          L          L
   B1        L         L          L         L          L          L
   B2        L         L          L         L          L          L
   B3        L         L          L         L          L          L
   B4        L         L          L         L          L          L
   C1        L         L          L       65 km      93 km        L
   C2        L         L          L       65 km      93 km        L
   C3        L         L          L       65 km      93 km        L
   C4        L         L          L         L        93 km        L
   D1        L         L          L         L          L          L
   D2        L         L          L         L          L          L
   D3        L         L          L         L          L          L
   D4        L         L          L         L          L          L
   E1        L         L          L         L          L          L
   E2        L         L          L         L          L          L
   E3        L         L          L         L          L          L
   E4        L         L          L         L          L          L
   F1        L         L          L         L          L          L
   F2        L         L          L         L          L          L
   F3        L         L          L         L          L          L
   F4        L         L          L         L          L          L
   G1        L         L          L       65 km        L          L
   G2        L         L          L       65 km        L          L
   G3        L         L          L       65 km        L          L
   G4        L         L          L       65 km        L          L
   H1        L         L          L         L          L          L
   H2        L         L          L         L          L          L
   H3        L         L          L         L          L          L




                               A-103
Channels   Honolulu   Jacksonville   Akron
    1         L            L           L
  2/2A        L            L           L
   A1         L            L           L
   A2         L            L           L
   A3         L            L           L
   A4         L            L           L
   B1         L          83 km         L
   B2         L            L           L
   B3         L          83 km         L
   B4         L            L           L
   C1         L            L           L
   C2         L            L           L
   C3         L            L           L
   C4         L            L           L
   D1         L            L           L
   D2         L            L           L
   D3         L            L           L
   D4         L            L           L
   E1         L            L           L
   E2         L            L           L
   E3         L            L           L
   E4         L            L           L
   F1         L            L           L
   F2         L            L           L
   F3         L            L           L
   F4         L            L           L
   G1         L            L           L
   G2         L            L           L
   G3         L            L           L
   G4         L            L           L
   H1         L            L           L
   H2         L            L           L
   H3         L            L           L




                  A-104
INTERIM REPORT
3G SPECTRUM STUDY
2500-2690 MHz BAND




                     THERE ARE NO APPENDICES

                          FOR SECTION 6




                              A-105

				
DOCUMENT INFO
Description: South Korean Government Microwave Frequencies Agreement document sample